Petitt v. Exigency Healthcare Services, LLC

Summary

The United States District Court for the Northern District of California approved a settlement resolving Anietta Petitt’s claims under the Fair Labor Standards Act, California Labor Code, and California’s Private Attorneys General Act. The court found the settlement fair and reasonable, including approximately $65,000 for Petitt’s individual claims and approximately $34,000 for PAGA penalties. The court awarded $48,000 in attorneys’ fees and $2,805.57 in costs.

Holdings

1. The court may approve an FLSA settlement when it reflects a fair and reasonable compromise of a bona fide dispute over FLSA provisions, and the settlement here satisfied that standard.
2. The court approved the PAGA settlement because it was fair, reasonable, and adequate in view of the risks of continued litigation and PAGA's purposes of remediating violations, deterring future violations, and maximizing enforcement of California labor laws.
3. The court awarded $48,000 in attorneys' fees and $2,805.57 in costs, reducing the requested fee award because the request exceeded the Ninth Circuit's common-fund benchmark and was insufficiently supported.

Questions Presented

1. Whether the parties' settlement of Petitt's individual FLSA claims constituted a fair and reasonable compromise of a bona fide dispute.
2. Whether the proposed settlement of Petitt's representative PAGA claims was fair, reasonable, and adequate and should be approved.
3. Whether the requested attorneys' fees and costs were reasonable and adequately supported.

Disposition

approved