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Martin, et al v. Spring Break '83 Prodn, L.L.C (5th Cir. 7.24.12)

Articles Discussing Case:

eLABORate: Fifth Circuit Reaffirms the Use Of, But Limits, Private Unsupervised FLSA Settlements

Phelps Dunbar LLP • June 08, 2015
In 2012, the Fifth Circuit decided Martin v Spring Break ’83, LLC, 688 F.3d 247 (5th Cir. 2012), holding that private settlements of FLSA claims involving bona fide disputes over hours worked or compensation owed are enforceable absent court supervision.

Fifth Circuit Holds that Approval Not Required by Court or Department of Labor for FLSA Settlement

Phelps Dunbar LLP • August 07, 2012
In Martin v. Spring Break ’83 Productions, LLC, No. 11-30671 (5th Cir. July 24, 2012), the Fifth Circuit Court of Appeals, addressing an issue of first impression, held that a union-negotiated settlement precluded plaintiffs, union members, from pursuing their claims under the Fair Labor Standards Act (“FLSA”) for unpaid wages, even though the settlement was never approved by the court or the Department of Labor (“DOL”). The ruling contravenes a long-standing Eleventh Circuit decision, Lynn’s Food Stores, Inc. v. United States, which had held that FLSA claims may not be settled without approval of the court or the DOL. The Fifth Circuit declined to read Lynn’s Food Stores to require approval from a court or the DOL in all instances, finding that settlement and waiver of FLSA claims may be effectuated without oversight in certain circumstances, such as those presented in Martin.

More FLSA Common Sense from the 5th Circuit - Settlement Without Supervision OK

Ogletree Deakins • July 30, 2012
After lamenting for some time the direction which FLSA law has been heading, it may be too soon to say that the inevitable swing back to the middle has begun, but there are encouraging signs and last week's decision in Martin, et al v. Spring Break '83 Prodn, L.L.C (5th Cir. 7.24.12) is yet another step.