Vines v. Welspun Pipes Inc., No. 20-2168 (8th Cir. 2021)Annotate this Case
After plaintiffs filed a class action against defendants under the Fair Labor Standards Act (FLSA) and the Arkansas Minimum Wage Act (AMWA), plaintiffs negotiated a settlement agreement with Welspun for the wage claim and attorneys' fees. However, the district court did not approve the settlement because it determined that the claim and fees were not separately negotiated. When the parties presented the district court with only the wage-claim portion of the settlement, the district court approved it. The district court subsequently partially granted plaintiffs' motion for an award of attorneys' fees and costs, awarding $1.00 in fees. Alternatively, the district court noted that it would award $25,000 in fees if $1.00 was improper.
The Eighth Circuit concluded that the district court did not clearly err when it denied the parties' joint motion for approval of the settlement based on its conclusion that the FLSA claims and the attorneys' fees were not separately negotiated. However, because the record contains no lodestar calculation, the court vacated the award of attorneys' fees. In this case, plaintiffs' claim was not frivolous or groundless, and it is unlikely that a $1.00 attorneys' fee is reasonable. Furthermore, the court cannot conduct a meaningful review of the district court's alternative award. The court declined to reassign the case and remanded for further proceedings.