O'Neal v. American Shaman Franchise Systems, Inc.

A franchisee settled FLSA and non-FLSA claims for $50,000 via a broad mutual release that was never approved by a court or the Department of Labor, then sued the same defendants for fraudulent transfer. The Eleventh Circuit held that Lynn's Food renders such a release unenforceable only as to the FLSA claims; whether the release bars the remaining state-law claims is a question of Florida contract law, under which the release was supported by independent consideration and fully enforceable. The court also affirmed summary judgment on the defendants' breach-of-contract counterclaim, construing the settlement's confidentiality provision so that a specific clause permitting disclosure to a court to obtain enforcement excused the general clause's court-order and prior-written-notice requirements.

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