11th Circuit: Earlier Settlement Offer Is Relevant In FLSA Fee Award

Mealey's (November 8, 2018, 11:04 AM EST) -- ATLANTA — The trial court properly awarded attorney fees that were less than what was requested following the settlement of former delivery drivers’ Fair Labor Standards Act (FLSA) minimum wage claims because, in calculating reasonable attorney fees, the trial court was permitted to consider the drivers’ rejection of earlier settlement offers and to consider the final results achieved compared to the recovery originally sought and to the requested fee award, the 11th Circuit U.S. Court of Appeals ruled Nov. 2 (Douglas Walker, et al. v. Iron Sushi LLC, et al., No. 18-10617, 11th Cir., 2018 U.S. App. LEXIS 31062)....