Melgar v. OK Foods, No. 17-2612 (8th Cir. 2018)Annotate this Case
Employees of a chicken processing plant filed a class action lawsuit, alleging their employer failed to pay certain wages in violation of Arkansas state law and the Fair Labor Standards Act (FLSA), 29 U.S.C. 201. More than 1,000 workers opted in. The class was subsequently decertified and claims were subjected to the two-year FLSA limitations period. The parties eventually settled their dispute out-of-court for a confidential amount made known to the court, which approved the agreement but declined to award the agreed-upon $87,500.00 in attorneys’ fees, costs, and expenses. The district court, sua sponte, reduced the fees awarded to $22,500.00. The Eighth Circuit remanded with instructions to award the agreed-upon fees. The attorneys’ fees-to-recovery ratio alone is not the sole determining factor. In light of the need to focus on multiple factors and not just one, and in light of the strong likelihood that the parties’ agreement is reasonable, any required review by the district court is light and the agreed-upon award is not outside the range of what would be approved.