The court-approval requirement for settlements under the Fair Labor Standards Act has long posed challenges for employers and employees alike. Since the U.S. Court of Appeals for the Eleventh Circuit's seminal decision in 1982 in Lynn's Food Stores v. United States holding that parties are required to obtain court approval of FLSA settlements in order to fully extinguish those claims, courts around the country largely have followed its requirements. As a result, in order to obtain a complete waiver of FLSA claims, parties either needed approval from a court or the U.S. Department of Labor.