Maggie Thomas v. State of Louisiana
1976 U.S. App. LEXIS 8209 · 22 Wage & Hour Cas. (BNA) 1146 · 534 F.2d 613
July 1, 1976 · Docket 75-1801
Opinion
The State of Louisiana challenges the lower court’s order setting aside its settlement agreement with 1,941 state employees in compromise of a claim for unpaid overtime compensation. Finding the agreement valid and binding, we reverse.
Appellees, employees of various state agencies who had sued their employer under the Fair Labor Standards Act (FLSA), 29 U.S.C. § 201 et seq. (1970),
Appellees persuaded the lower court to void the settlement agreement on the authority of Schulte v. Gangi, 328 U.S. 108, 66 S.Ct. 925, 90 L.Ed. 1114 (1946), which held that the remedy of liquidated damages under the FLSA cannot be bargained away by an agreement between employer and employee in settlement of a bona fide dispute over whether the employer was subject to the FLSA. Basing its decision on the danger that one-sided bargaining might frustrate the congressional purpose of insuring minimum wage payments,
Although no court ever approved this settlement agreement, the same reason for enforcing a court-approved agreement — i. e., little danger of employees being disadvantaged by unequal bargaining power— applies here. Initially, appellees had three alternatives to filing suit in federal court. First, they could have requested the Secretary of Labor to exercise his discretionary power under 29 U.S.C. § 216(c) (1970) to intervene and prosecute the action in their behalf in a federal proceeding, but they would thereby have waived their claim to liquidated damages and attorneys’ fees.
Settlement agreements have always been a favored means of resolving disputes.
REVERSED.
. Section 16(b) of the FLSA read at the time:
Any employer who violates the provisions of section 206 [prescribing a minimum wage] or section 207 [prescribing maximum hours and overtime rates (section (h))] of this title shall be liable to the employee or employees affected in the amount of their unpaid minimum wages, or their unpaid overtime compensation, as the case may be, and in an additional equal amount as liquidated damages. Action to recover such liability may be maintained in any court of competent jurisdiction by any one or more employees for and in behalf of himself or themselves and other employees similarly situated. . . . The court in such action shall, in addition to any judgment awarded to the plaintiff or plaintiffs, allow a reasonable attorney’s fee to be paid by the defendant, and costs of the action.
29 U.S.C. § 216(b) (1970).
. The Court in Parden v. Terminal Ry., 377 U.S. 184, 84 S.Ct. 1207, 12 L.Ed.2d 233 (1964), had held that while a state is immune from suit by an individual unless it consents, Congress can condition the state’s decision to engage in some activity within Congress’ power to regulate commerce on a waiver of immunity. The Employees Court recognized that while Parden involved a railroad business that the state there operated for profit, Congress could regulate working conditions of employees in state institutions not conducted for profit if it determined that those employees “have such a relation to interstate commerce that national policy, of which Congress is the keeper, indicates that their status should be raised.” 411 U.S. at 284, 93 S.Ct. at 1618.
. While the Secretary of Labor could have sued in their behalf, see text accompanying note 7 infra, he had not chosen to do so.
. The second sentence of section 16(b) was amended to read as follows:
Action to recover such liability may be maintained against any employer (including a public agency) in any Federal or State court of competent jurisdiction by any one or more employees for and in behalf of himself or themselves and other employees similarly situated.
29 U.S.C.A. § 216(b) (Supp.1976).
. See also Brooklyn Sav. Bank v. O’Neal, 324 U.S. 697, 706-07, 65 S.Ct. 895, 89 L.Ed. 1296 (1944).
. See Urbino v. Puerto Rico Ry. L & P Co., 164 F.2d 12 (1st Cir. 1947); Jarrard v. Southeastern Shipbuilding Corp., 163 F.2d 960 (5th Cir. 1947); Bracey v. Luray, 161 F.2d 128 (4th Cir.), cert. denied, 332 U.S. 790, 68 S.Ct. 98, 92 L.Ed. 372 (1947); cf. Satterwhite v. United Parcel Serv., Inc., 496 F.2d 448 (10th Cir.), cert. denied, 419 U.S. 1079, 95 S.Ct. 668, 42 L.Ed.2d 674 (1974) (employees cannot challenge denial of liquidated damages for claim submitted to binding arbitration).
. While retaining the right to recover for three (rather than two) years of compensation if they could prove, as the lower court found here, that the violations were willful. See Brennan v. Heard, 491 F.2d 1, 2-3 (5th Cir. 1974).
. See, e. g., Williams v. First Nat’l Bank, 216 U.S. 582, 595, 30 S.Ct. 441, 54 L.Ed. 625 (1910).
. See, e. g., Cia Anon Venezolana De Navigacion v. Harris, 374 F.2d 33, 35 (5th Cir. 1967).