Back v. Ray Jones Trucking, Inc.

Summary

The United States District Court for the Western District of Kentucky granted final approval of a $450,000 settlement resolving claims that Ray Jones Trucking and related defendants failed to pay overtime wages under the Fair Labor Standards Act and Kentucky Wage and Hour Act. The court conditionally certified a 54-member settlement class, found the settlement fair, reasonable, and adequate, and approved attorney’s fees of $150,000, litigation costs of $4,571.10, and a $20,000 service award to the named plaintiff.

Holdings

1. The Settlement Class satisfies the requirements of Rule 23(a) (numerosity, commonality, typicality, and adequacy of representation) and Rule 23(b)(3) (predominance and superiority), and is conditionally certified for purposes of settlement.
2. The settlement agreement is fair, reasonable, and adequate based on the Rule 23(e)(2) factors (adequacy of representation, arm's-length negotiation, adequate relief, equitable treatment) and the Sixth Circuit factors (risk of fraud/collusion, complexity, discovery, likelihood of success, counsel opinions, class member reaction, public interest).
3. Attorney's fees of $150,000 are reasonable using the percentage-of-the-fund method, cross-checked by the lodestar method.
4. Reimbursement of $4,571.10 in litigation costs is approved.
5. A service award of $20,000 to Plaintiff is approved.

Questions Presented

1. Whether the proposed settlement class should be finally certified for purposes of settlement under Federal Rule of Civil Procedure 23
2. Whether the proposed settlement agreement is fair, reasonable, and adequate under Federal Rule of Civil Procedure 23(e)
3. Whether plaintiff's requested attorney's fees, litigation costs, and service award should be approved

Disposition

approved