The U.S. Court of Appeals for the First Circuit is reviewing a employment law dispute that highlights the complexities of settlement enforcement in wage and hour litigation. The case, *Maccarone v. Siemens Industry, Inc.* (1st Cir. 2026), involves Ann Marie Maccarone's claims against her former employer for alleged violations of federal and state wage laws.
Maccarone initially filed suit in Rhode Island Superior Court, alleging violations of the Fair Labor Standards Act and Rhode Island wage and hour laws against Siemens Industry, Inc. The case was removed to federal court by Siemens on June 15, 2020, landing in the U.S. District Court for the District of Rhode Island before Judge John J. McConnell, Jr.
The litigation proceeded through discovery over several years. On Dec. 15, 2023, the district court issued a mixed ruling on Siemens' motion for summary judgment, granting it in part and denying it in part. The court's decision left only Maccarone's FLSA claims viable for trial, eliminating her state law wage and hour claims. The court subsequently scheduled jury selection to begin on April 29, 2024.
The case took a significant turn on March 6, 2024, when both parties participated in a court-annexed settlement conference before a magistrate judge. Maccarone appeared via Zoom for the mediation session, while other participants attended in person. During this conference, the parties reached what appeared to be a comprehensive oral settlement agreement.
According to the First Circuit's opinion, the magistrate judge recited the essential terms of the settlement agreement on the record, which was captured by audio recording. The agreed-upon terms were substantive and detailed, including several key provisions that are standard in employment settlement agreements.
Under the oral agreement, Siemens would pay Maccarone a specified sum of money within approximately 30 days after the execution of formal settlement paperwork. The settlement was to include typical restrictive provisions found in employment disputes, including non-defamation clauses preventing either party from making disparaging statements about the other, no-rehire provisions preventing Maccarone from seeking reemployment with Siemens, and confidentiality provisions restricting disclosure of the settlement terms.
Additionally, the agreement provided that the federal lawsuit would be dismissed with prejudice, meaning Maccarone could not refile the same claims. Each party would bear its own attorney fees and costs, rather than seeking reimbursement from the other side. The agreement also included a full mutual release, meaning both parties would waive any future claims against each other related to the employment relationship and underlying dispute.
Despite reaching this apparent resolution during the court-supervised mediation, the settlement agreement was ultimately "disregarded," according to Circuit Judge Gelpí's opinion. The First Circuit's description of the case as stemming from "a disregarded settlement agreement" suggests that one or both parties failed to honor the terms reached during the March 2024 mediation session.
The case is now before the First Circuit panel consisting of Circuit Judges Gelpí, Lynch, and Howard. Maccarone is represented by Sonja Linnea Deyoe of the Law Offices of Sonja L. Deyoe, while Siemens is represented by attorneys Jillian S. Folger-Hartwell and Dimitrios Markos from the employment law firm Littler Mendelson.
The dispute raises important questions about the enforceability of oral settlement agreements reached during court-annexed mediation sessions. While settlement agreements are generally favored by courts as a means of resolving disputes efficiently, questions can arise about whether parties are bound by oral agreements or whether written documentation is required for enforcement.
FLSA cases often involve complex calculations of overtime pay, minimum wage violations, and potential liquidated damages. The statute allows employees to recover unpaid wages plus an equal amount in liquidated damages, along with attorney fees in successful cases. This can create significant financial exposure for employers, making settlement an attractive option for both sides.
The timing of the settlement discussions is notable, occurring just weeks before the scheduled trial date. This suggests both parties may have been motivated to avoid the uncertainty and expense of trial, only to have the agreement fall apart for reasons not yet detailed in the available record.
The First Circuit's review will likely focus on the circumstances surrounding the breakdown of the settlement agreement and determine what remedies, if any, are available to the parties. The court may also address broader questions about the enforceability of oral agreements reached during judicial mediation sessions.
This case demonstrates the ongoing challenges in employment litigation, where the intersection of federal wage and hour laws, state employment statutes, and settlement procedures can create complex legal scenarios that require appellate review for resolution.