The First Circuit Court of Appeals ruled Tuesday that the Wheatleigh Corporation must honor a comprehensive settlement agreement that resolved wage and hour claims brought by former employees of its luxury Massachusetts hotel.
In *Mongue v. The Wheatleigh Corporation*, the appeals court affirmed the district court's decision to enforce a global settlement negotiated by a single attorney representing both individual plaintiffs and a certified class of employees. The hotel corporation had argued that the settlement should be invalidated because plaintiffs' counsel should not have been permitted to represent both individual and class plaintiffs simultaneously.
The case originated with a lawsuit filed April 11, 2018, by Mark Brown, a former guest services manager at the Wheatleigh Hotel, a luxury resort located in Lenox, Massachusetts. Brown sued the hotel's owner, the Wheatleigh Corporation, along with its executives: president, treasurer, and director L. Linfield Simon; secretary and director Susan Simon; and general manager and director Marc Wilhelm.
Brown's initial complaint spawned what Circuit Judge Kayatta described as "a series of lawsuits" brought by former employees against the hotel and its operators. The litigation included both individual employment claims and a certified class action alleging unfair wage practices.
The complexity of the case increased as multiple former employees joined the litigation, leading to what the court characterized as overlapping claims requiring coordinated legal representation. A single attorney ultimately negotiated on behalf of all plaintiffs - both those pursuing individual claims and the certified class members - to reach a comprehensive resolution.
The global settlement agreement was designed to resolve all outstanding wage and hour claims against the hotel and its ownership. However, after the settlement was negotiated, the Wheatleigh Corporation attempted to escape its obligations under the deal.
The hotel corporation's primary argument focused on what it characterized as a conflict of interest in the plaintiffs' legal representation. Wheatleigh contended that allowing one attorney to represent both individual plaintiffs and class members in settlement negotiations created an improper dual representation that should invalidate the entire agreement.
The U.S. District Court for the District of Massachusetts, presiding under Magistrate Judge Katherine A. Robertson, rejected Wheatleigh's arguments and enforced the settlement. The hotel corporation then appealed to the First Circuit, seeking to overturn the district court's ruling.
The First Circuit panel, consisting of Circuit Judges Gelpí and Kayatta, along with District Judge Smith of the District of Rhode Island sitting by designation, heard oral arguments in the case. Matthew P. Horvitz of Goulston & Storrs PC represented the appellants, while Jeffrey S. Morneau of Connor & Morneau, LLP argued for the appellee.
In its January 21, 2026 opinion, the First Circuit firmly rejected Wheatleigh's attempts to void the settlement agreement. Circuit Judge Kayatta, writing for the court, emphasized that the district court had properly evaluated the settlement arrangement and found no improper conflict in the legal representation.
The appeals court's decision reinforces important precedent regarding class action settlements and the scope of permissible legal representation in complex employment litigation. The ruling suggests that courts will carefully scrutinize attempts by defendants to escape settlement obligations after agreements have been negotiated in good faith.
The case also highlights the challenges faced by hospitality industry workers seeking to vindicate their wage and hour rights. The Wheatleigh Hotel, described as a luxury resort, employed numerous workers whose wage claims ultimately required class action treatment to achieve an efficient resolution.
For employment law practitioners, the decision provides guidance on the permissible scope of representation in cases involving both individual and class claims. The First Circuit's affirmance suggests that courts will not readily find conflicts of interest where attorneys negotiate comprehensive settlements that benefit all affected parties.
The ruling also demonstrates judicial reluctance to allow defendants to escape settlement agreements based on procedural challenges to plaintiffs' representation, particularly where those challenges are raised only after settlement terms have been negotiated.
The decision comes at a time when wage and hour litigation continues to be a significant area of employment law, with workers in the hospitality industry frequently bringing claims for unpaid overtime, improper tip handling, and other compensation violations.
Wheatleigh's unsuccessful appeal effort illustrates the difficulty defendants face when attempting to void settlements based on challenges to opposing counsel's representation structure, particularly in cases where the settlement appears to provide fair compensation to affected workers.
The First Circuit's decision is final unless the defendants seek further review from the Supreme Court, though such petitions in employment settlement cases are rarely granted certiorari. The ruling ensures that the former Wheatleigh Hotel employees will receive the compensation negotiated in their settlement agreement.