Canaday v. The Anthem Companies, Inc.

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IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF TENNESSEE
EASTERN DIVISION
______________________________________________________________________________
LAURA CANADAY, individually and on
behalf of all others similarly situated,
Plaintiff,
v. 	No. 1:19-cv-01084-STA-jay
THE ANTHEM COMPANIES, INC.,
Defendant.
______________________________________________________________________________
ORDER ON JOINT NOTICE OF SETTLEMENT
______________________________________________________________________________
On January 26, 2026, the parties filed a Joint Notice of Settlement (ECF No. 170), reporting
that they had reached an out-of-court agreement to resolve their dispute. Local Rule 83.13(b)
requires the parties to any civil action to promptly notify the presiding judge if they reach a
settlement. The Rule then gives the parties 28 days to file a final stipulation or motion for dismissal.
The Court finds that the parties have satisfied the notice of settlement required by Local Rule
83.13(b). The Court hereby continues the non-jury trial set for February 23, 2026, and the pretrial
conference set for February 13, 2026.
Instead of the 28 days granted under the Local Rules for filing a motion or stipulation of
dismissal, the parties have requested 45 days to file a motion for approval of their settlement. In
Fair Labor Standards Acts cases, the parties must take the additional step of seeking court approval
of any settlement agreement. A district court must scrutinize a proposed FLSA settlement for
fairness and determine whether it is a “fair and reasonable resolution of a bona fide dispute over
FLSA provisions.” Lynn’s Food Stores, Inc. v. United States ex rel. U.S. Dep’t of Labor, 679 F.2d
1350, 1355 (11th Cir. 1982); Steele v. Staffmark Invs., LLC, 172 F. Supp. 3d 1024, 1026 (W.D.
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Tenn. 2016) (noting the circuit split over “whether settlements or stipulations of dismissal for
FLSA claims require court approval” and the fact that the “Sixth Circuit has yet to rule definitively
on the question”). In this analysis, the Court examines three factors: (1) whether the settlement
was achieved in an adversarial context, (2) whether the plaintiffs were represented by attorneys
who can protect their rights and (3) whether the settlement reflects a fair and reasonable
compromise of the issues in dispute. Lynn’s Food Stores, 679 F.2d at 1354.
The parties’ request to have 45 days in which to file a joint motion for approval of their
FLSA settlement is GRANTED. The parties’ joint motion is therefore due on or before March 12,
2026.
IT IS SO ORDERED.
s/ S. Thomas Anderson
S. THOMAS ANDERSON
UNITED STATES DISTRICT JUDGE
Date: January 26, 2026
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