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Bodle v. TXL Mortgage Corporation

Articles Discussing Case:

Fifth Circuit Finds Settlement Agreement Did Not Release Employees’ FLSA Claims

Ogletree Deakins • June 11, 2015
In Bodle v. TXL Mortgage Corp., No. 14-20224 (June 1, 2015), the Fifth Circuit Court of Appeals held that a generic, broad-form settlement release between an employer and two of its former employees did not bar those employees’ subsequent lawsuit under the Fair Labor Standards Act (FLSA) for alleged overtime violations.

Fifth Circuit Reaffirms that Private Settlements of FLSA Claims May Be Enforceable When There is a Bona Fide Liability Dispute

Littler Mendelson, P.C. • June 04, 2015
On June 1, 2015, in Bodle v. TXL Mortgage Corporation, the U.S. Court of Appeals for the Fifth Circuit recognized established precedent1 that parties may privately settle and release wage claims that include a bona fide dispute as to liability (e.g., hours worked or compensation owed). But, the court also refused to find a prior state court settlement agreement enforceable as to overtime claims brought under the Fair Labor Standards Act (FLSA) because there was no mention or factual development of any claim of unpaid overtime or a bona fide dispute as to hours worked or compensation owed under the FLSA in the prior state court case and its settlement negotiations.

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