For 40 years, the majority of federal courts have followed the holding of Lynn’s Food Stores, Inc. v. U.S., 679 F.2d 1350 (11th Cir. 1982), that FLSA claims may be settled only through approval by the U.S. Department of Labor (DOL) or through a lawsuit filed by the individual, in which a court of competent jurisdiction enters a stipulated judgment, after reviewing the proposed settlement for fairness. Some other courts of appeals, either directly or indirectly, have reached the same conclusion. Increasingly, however, courts are questioning whether these holdings are sound law.

In this special report, leaders of Jackson Lewis’ Class Actions and Complex Litigation and Wage and Hour Practice Groups look at the current state of the law on required court approval of FLSA claims, including claims brought as collective actions.

Has Lynn’s Food Grown Stale? Courts Increasingly Question Obligation to Review FLSA Settlements

Photo of David T. Wiley David T. Wiley

David T. Wiley is the Knowledge Management (“KM”) Attorney for Jackson Lewis P.C.’s Wage and Hour Practice Group, and is based in the Birmingham, Alabama, office.

Mr. Wiley creates and manages legal and electronic resources and materials to provide innovative client services; serves…

David T. Wiley is the Knowledge Management (“KM”) Attorney for Jackson Lewis P.C.’s Wage and Hour Practice Group, and is based in the Birmingham, Alabama, office.

Mr. Wiley creates and manages legal and electronic resources and materials to provide innovative client services; serves as a resource for other practice group members; monitors and analyzes regulatory and case law developments; and contributes to the firm’s blogs and legal updates. In his knowledge management role, Mr. Wiley draws on more than two decades of training, advising, and representing employers nationwide in federal and state courts and before administrative agencies on a variety of employment-related issues, including collective and class actions and all manner of discrimination and retaliation claims.

Prior to obtaining his MBA and law degrees, Mr. Wiley served six distinguished years as an officer in the United States Navy Supply Corps. While attending law school, Mr. Wiley was the Senior Articles Editor for the Georgia Law Review.

Photo of Eric R. Magnus Eric R. Magnus

Eric R. Magnus is a principal in the Atlanta, Georgia, office of Jackson Lewis P.C. He is co-leader of the Class Actions and Complex Litigation practice group. His practice is focused on defending federal and state wage and hour class and collective actions…

Eric R. Magnus is a principal in the Atlanta, Georgia, office of Jackson Lewis P.C. He is co-leader of the Class Actions and Complex Litigation practice group. His practice is focused on defending federal and state wage and hour class and collective actions in jurisdictions across the United States.

Photo of David R. Golder David R. Golder

David R. Golder is a principal in the Hartford, Connecticut, office of Jackson Lewis P.C. He is co-leader of the Class Actions and Complex Litigation practice group.