Thomas O'Neal v. Ameircan Shaman Franchise System, Inc., et al.

Tampa, Florida, employment law lawyer represented the Plaintiff on a Fair Labor Standards Act violation theory.

We have held that a settlement agreement bars litigation of
wage-and-hour claims under the Fair Labor Standards Act only if
the settlement was approved by a court or the Department of La-
bor. See Lynn’s Food Stores, Inc. v. United States, 679 F.2d 1350, 1352–
53 (11th Cir. 1982). In this appeal, we must now decide how this
rule applies when FLSA claims are settled alongside non-FLSA
claims. After Thomas O’Neal sued American Shaman on several
legal theories, including the FLSA, he signed a settlement agree-
ment that released “any and all” claims in return for several thou-
sand dollars. Neither a court nor the Department of Labor ap-
proved the settlement. So, when O’Neal later sued American
Shaman again—this time, for fraudulent transfer—he argued that
American Shaman could not enforce the release. The district court
rejected this position and dismissed O’Neal’s new complaint.
We believe that, because of the settlement agreement, the
district court correctly dismissed O’Neal’s fraudulent transfer
claims. Our interpretation of the FLSA in Lynn’s Food does not im-
pose a federal-law impediment to the release of non-FLSA claims.
It is true that the parties’ failure to secure preapproval for their set-
tlement means the settlement cannot bar litigation of O’Neal’s

FLSA claims. But the enforceability of the release as to non-FLSA
claims is a matter of state contract law, not federal FLSA law.

Affirmed