“Stipulated Prevailing Status” and the Lodestar’s Resilience:
Eleventh Circuit Affirms Full Attorneys’-Fee Recovery in FLSA Settlements (Becton & Barker v. WBY, Inc.)

Introduction

This commentary dissects the Eleventh Circuit’s consolidated non-published opinion in Soraya Barker v. WBY, Inc., Nos. 24-11361 & 24-11362 (Aug. 22, 2025), which affirmed sizeable fee awards to three plaintiff-side law firms following Fair Labor Standards Act (FLSA) settlements. The Court addressed two principal challenges: (i) whether the district court should have reduced the lodestar because the entertainers and waitresses achieved only “partial” monetary success, and (ii) whether the hours claimed were excessive or duplicative. The defendants—an Atlanta strip club (Follies), its corporate owner WBY, Inc., and two individual owners—lost on both fronts.

Summary of the Judgment

The Eleventh Circuit unanimously held that the district court acted within its discretion by:

• Refusing to diminish the lodestar despite the plaintiffs’ settlements being less than their theoretical maximum damages, because the parties expressly stipulated that all plaintiffs were “prevailing parties” for fee purposes and because vindicating FLSA rights carries intrinsic public value.
• Accepting, with minor adjustments, the hours and rates claimed by Dudley Law, Jones & Walden, and Flynn Law Firm, after finding the defendants’ objections too generalized and inadequately supported.

Consequently, fee awards exceeding $1.6 million—substantially more than the plaintiffs’ combined cash recovery—were affirmed in full.

Analysis

Precedents Cited and Their Influence

• Hensley v. Eckerhart, 461 U.S. 424 (1983) – Established the lodestar (reasonable hours × reasonable rate) as the starting point and emphasized the strong presumption that the resulting figure is reasonable. The panel repeatedly echoed this presumption.
• Resolution Trust Corp. v. Hallmark Builders, 996 F.2d 1144 (11th Cir. 1993) & Yellow Pages Photos, Inc. v. Ziplocal, 846 F.3d 1159 (11th Cir. 2017) – Confirmed that downward adjustments to a correct lodestar are “rare” and limited to situations where the lodestar fails to account for factors such as limited success. The Court held those situations were absent here.
• Johnston v. Borders, 36 F.4th 1254 (11th Cir. 2022) – Restated the “strong presumption” language, which the panel quoted in full.
• Norman v. Housing Authority of Montgomery, 836 F.2d 1292 (11th Cir. 1988); Loranger v. Stierheim, 10 F.3d 776 (11th Cir. 1994); ACLU v. Barnes, 168 F.3d 423 (11th Cir. 1999) – Provided the framework for evaluating billing records, requiring both fee applicants to exercise “billing judgment” and fee opponents to lodge “specific and reasonably precise” objections. The opinion found the defendants’ objections wanting under this standard.
• Parker v. DeKalb Chrysler-Plymouth, 673 F.2d 1178 (11th Cir. 1982) – Cited to highlight the public-policy rationale for mandatory FLSA fee-shifting. The panel leveraged this policy to justify refusing to discount the lodestar.
• Distinguished Authorities – Defendants invoked civil-rights fee cases (Farrar v. Hobby, Popham v. City of Kennesaw), Rule 68 (Vasconcelo), and enhancement precedent (Perdue v. Kenny A.). The Court distinguished them because: (a) FLSA fees are mandatory, not discretionary; (b) the plaintiffs accepted, not rejected, settlement offers; and (c) no enhancement was given—only the unvarnished lodestar.

Legal Reasoning

1. Prevailing-party Stipulation Controls. The settlement agreements explicitly labeled each plaintiff a “prevailing party within the meaning of 29 U.S.C. § 216”—solely for fee purposes. That stipulation foreclosed defendants’ limited-success argument because the statutory prerequisite for fees (prevailing status) was contractually and judicially satisfied.
2. Intrinsic Value of FLSA Enforcement. Citing Parker, the Court reaffirmed that FLSA litigation serves a public as well as private purpose; therefore, even modest damages or non-existent liquidated damages do not mandate fee reductions.
3. Specificity Requirement for Objections. Applying Norman/Barnes, the panel endorsed the district court’s refusal to perform an hour-by-hour autopsy where objections were “conclusory,” “cut-and-paste,” or “undecipherable.” The onus lies on defendants to isolate duplicative entries with precision.
4. No Mathematical Damages-to-Fees Ratio. Borrowing from Hensley n.40, the Court rejected a mere “cash-register” approach that divides damages recovered by damages sought. Given the pervasive absence of employer wage records, settlement figures were inherently imprecise and could not serve as the sole yardstick.
5. Bankruptcy-Court Work is Recoverable. Substantial attorney time was spent in WBY’s Chapter 11 case (13 hearings, contempt motions, plan modifications). The panel accepted the district court’s view that bankruptcy work was “integral” to protecting and monetizing FLSA claims and therefore compensable.

Impact on Future Litigation

• Reinforces the Strength of the Lodestar. Parties settling FLSA actions should realize that courts in the Eleventh Circuit are unlikely to trim a well-supported lodestar merely because the dollar recovery is moderate.
• Heightens Defense Burden. Defendants must lodge granular challenges—e.g., spreadsheet-level notations linking each contested time entry to duplicative effort—or risk wholesale rejection.
• Influences Settlement Strategy. Employers may weigh fee exposure more heavily when evaluating settlement offers; conversely, plaintiffs’ counsel can litigate aggressively, knowing fee recovery is robust so long as prevailing-party status is stipulated or established.
• Bankruptcy Overlay. Work required to navigate a defendant-employer’s bankruptcy is recoverable under § 216(b) when it safeguards FLSA recovery—a point of growing importance in industries susceptible to insolvency.
• Clarifies “Partial Success.” Where parties stipulate prevailing status, and the case accomplishes statutory vindication, courts may find the degree of monetary success immaterial.

Complex Concepts Simplified

• Lodestar Method. Calculate the hours reasonably spent × a reasonable hourly rate. The product is presumptively the correct fee unless exceptional factors dictate adjustment.
• Prevailing Party in FLSA Cases. A plaintiff “prevails” if they obtain a material alteration in the legal relationship—here, settlement payments plus a stipulation of prevailing status.
• Billing Judgment. Lawyers must omit hours they would not bill a paying client; entries must be specific enough to identify task, date, and time spent.
• Specificity Requirement for Objections. The opposing party must tie each alleged defect to a concrete time entry; broad labels like “excessive” are insufficient.
• Automatic Stay & Plan Modification (Bankruptcy). Filing Chapter 11 generally halts litigation; plaintiffs here obtained stay relief to press FLSA claims and later fought proposed plan changes that would have gutted recovery.

Conclusion

Becton & Barker v. WBY fortifies two doctrinal pillars: the lodestar’s durability and the FLSA’s public-interest mandate. When parties concede prevailing status, and fee opponents fail to mount highly specific objections, the lodestar will stand unreduced—even if fees dwarf damages. The decision will resonate across wage-and-hour litigation, bankruptcy-laden employment disputes, and fee-shifting jurisprudence in the Eleventh Circuit, offering clear guidance: stipulate with caution, object with precision, and never underestimate the statutory weight accorded to enforcing workers’ wage rights.