United States District Court, D. Maryland
RICHARD D. BENNETT, District Judge.
Plaintiff Brian Campbell ("Mr. Campbell") has filed this action against Defendant Center for Social Change, Inc. ("the Center") for alleged violations of the anti-retaliation provision of the Fair Labor Standards Act, 29 U.S.C. § 215(a)(3), and the Maryland Wage Payment and Collection law, Md. Ann. Code, Labor & Employment §§ 3-501 et seq. ; wrongful discharge; and defamation. Currently pending before this Court is the parties' Joint Motion to Approve Settlement (ECF No. 18) and Joint Motion for Reconsideration and to Seal the Joint Motion to Approve Settlement, construed as a Motion to Seal ("Joint Motion to Seal") (ECF No. 19). The parties' submissions have been reviewed and no hearing is necessary. See Local Rule 105.6 (D. Md. 2014). For the reasons that follow, the Joint Motion to Approve Settlement (ECF No. 18) is GRANTED and the Joint Motion to Seal (ECF No. 19) is GRANTED.
The parties have stipulated to the following facts. In December 2013, Plaintiff Brian Campbell received a jury summons from the Circuit Court for Baltimore County. Joint Mot. to Approve Settlement Ex. 1, 1, ECF No. 18-1. At this time, Mr. Campbell was employed as an "IP Specialist" by Defendant Center for Social Change. Id. On January 7, 2014, he was selected as a juror for a four-week trial, but the Center did not pay him during the duration of his service. Id. Believing this failure to pay to be a violation 29 C.F.R. 541.602,  Mr. Campbell's attorney wrote to the Center to demand payment. Id. When Mr. Campbell returned to work after the conclusion of the trial, the Center paid him the unpaid wages at issue, but then terminated him for "serious performance issues." Id. at 1-2.
As a result of his termination, Mr. Campbell filed the present action, asserting claims under the anti-retaliation provision of the Fair Labor Standards Act, 29 U.S.C. § 215(a)(3), and the Maryland Wage Payment and Collection Law, Md. Ann. Code, Labor & Employment §§ 3-501 et seq., as well as wrongful discharge and defamation. See Compl. ¶¶ 13-21, ECF No. 1. The Center answered Mr. Campbell's Complaint, arguing that it fired him for legitimate, non-retaliatory motives. Def.'s Answer, 6, ECF No. 6. The parties commenced discovery, but quickly realized that comprehensive discovery would be lengthy and expensive given Mr. Campbell's allegations and the Center's defenses. Joint Mot. to Approve Settlement Ex. 1, at 3. At that point, Mr. Campbell had been unable to find employment, thus he was further motivated to settle with the Center. Id. at 4.
The parties reached a settlement in which the Center would pay Mr. Campbell a total sum of $90, 000 in return for his release of all claims. Joint Mot. to Approve Settlement Ex. 2, 1-2, ECF No. 18-2. The Center's insurer does not provide coverage of legal fees, thus the settlement agreement did not include a specific provision for attorney's fees. Joint Mot. to Approve Settlement Ex. 1, at 7.
Although the parties dispute whether this Court's approval is required, they filed the pending Joint Motion to Approve Settlement (ECF No. 18) to achieve finality in their dispute. The parties subsequently filed the Joint Motion to Seal (ECF No. 19).
STANDARDS OF REVIEW
A. Approval of Fair Labor Standards Act Settlements
The Fair Labor Standards Act ("the FLSA") protects workers from the low wages and long hours that may arise from the significant inequality in bargaining position between an employer and the employees. The requirements of the FLSA are thus mandatory, generally precluding the parties from bargaining, modifying, or waiving the terms by contract or settlement. See Brooklyn Sav. Bank v. O'Neil, 324 U.S. 697, 706 (1945). An exception to this general rule is court-approved settlement. See Saman v. LBDP, Inc., No. DKC-12-1083, 2013 WL 2949047, at *2 (D. Md. June 13, 2013). A court may approve settlement under the FLSA only if the "settlement reflects a reasonable compromise of disputed issues' rather than a mere waiver of statutory rights brought about by an employer's overreaching.'" Id. (quoting Lynn's Food Stores, Inc. v. United States, 679 F.2d 1350, 1354 (11th Cir. 1982)).
B. Sealing of Court Records
The "public and the press" possess a "qualified right of access to judicial documents, " as judicial proceedings are "presumptively open to public scrutiny." Doe v. Public Citizen, 749 F.3d 246, 265 (4th Cir. 2014); see also Nixon v. Warner Communications, Inc., 435 U.S. 589, 597 (1978). A court, however, may seal the specified documents if "competing interests" dwarf public access concerns. In re Knight Pub. Co., 743 F.2d 231, 235 (4th Cir. 1984); see also Kianpour v. Restaurant Zone, Inc., No. DKC-11-0802, 2011 WL 3880463, at *1 (D. Md. Aug. 30, 2011). In the Fourth Circuit, parties moving to seal must satisfy the requirements of Local Rule 105.11 and provide the court with "(a) proposed reasons supported by specific factual representations to justify the sealing and (b) an explanation why alternatives to sealing would not provide sufficient protection." See Kianpour, 2011 WL 3880463, at *1.
A. Joint Motion to Approve ...