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Lynn’s Food Stores, Inc. v. United States

Articles Discussing Case:

Cracking the Door? The Eleventh Circuit Again Considers When Out-of-Court FLSA Settlements Are Enforceable

Ogletree Deakins • August 13, 2013
n 1982, the Eleventh Circuit Court of Appeals held in Lynn’s Food Stores, Inc. v. United States that employers and employees cannot settle claims under the Fair Labor Standards Act (FLSA) unless (1) the settlement is supervised by the U.S. Secretary of Labor, or (2) a court enters a stipulated judgment after “scrutinizing the settlement for fairness.” Since then, most federal district courts (not just those in the Eleventh Circuit) have followed this ruling, routinely holding that out-of-court settlement agreements, to the extent that they purport to waive FLSA claims, are per se unenforceable.