## Facts

- Multiple plaintiffs filed and later consolidated Title VII actions alleging Bell Helicopter discriminated against Black employees and female employees.
- The district court designated lead and associate class counsel after counsel could not agree on division of responsibilities.
- The court conditionally certified a Rule 23(b)(2) class and the parties completed extensive discovery before trial.
- On the eve of trial, the parties reached a tentative settlement; a proposed settlement was later submitted for preliminary approval.
- Most named plaintiffs initially accepted the tentative agreement subject to Bell meeting additional individual demands; Bell made lower individual offers, and 10 of 11 named plaintiffs then opposed the settlement.
- Most objecting named plaintiffs discharged their original attorneys; one named plaintiff supported the settlement and remained aligned with class counsel.
- The proposed settlement included a monetary fund (reported as $1.25 million) plus injunctive and equitable relief (reported as roughly $1 million in estimated value).
- The district court severed the objecting named plaintiffs’ individual claims from the class action and proceeded to evaluate the class settlement.
- After considering objections, the district court approved the settlement as fair and reasonable and awarded attorneys’ fees and costs to class counsel.
- The objecting named plaintiffs and one attorney appealed the settlement approval and the fee award.

## Issues

1. Whether the district court abused its discretion in approving the class settlement as fair, adequate, and reasonable under Rule 23(e).
2. Whether class counsel fairly and adequately represented the class during settlement negotiations despite opposition from most named plaintiffs.
3. Whether the attorneys’ fee award created an impermissible conflict between class counsel and the class or was otherwise an abuse of discretion.

## Decision

- The Fifth Circuit affirmed the district court’s approval of the settlement and its award of attorneys’ fees and costs.
- The court applied a deferential abuse-of-discretion standard, citing a strong policy favoring settlement.
- The settlement was within a reasonable range given litigation complexity, discovery completed, risks on the merits, and the benefits obtained for the class.
- Objections by most named plaintiffs did not control because the fairness inquiry focuses on the class as a whole, not individualized dissatisfaction with personal recoveries.
- The record supported that class counsel’s work (including significant discovery and negotiation) adequately represented the class.
- The fee award, set under judicial oversight and established criteria, did not by itself show a conflict or that counsel traded class relief for fees.

## Legal Principles

- Appellate review of a district court’s approval of a class settlement is limited to whether the court abused its discretion.
- Rule 23(e) approval turns on whether the settlement is fair, adequate, and reasonable in light of the case posture, litigation risks, and the settlement’s value to the class.
- Opposition by named plaintiffs does not automatically defeat settlement approval; the relevant beneficiary is the class as a whole.
- Adequacy of class representation is assessed by counsel’s overall performance for the class, including preparation and negotiation, and the absence of demonstrated conflicting interests.
- A court-approved attorneys’ fee award, determined through independent judicial evaluation, is not improper absent evidence that fees distorted counsel’s representation of the class.

## Conclusion

The Fifth Circuit upheld a district court’s Rule 23(e) approval of a Title VII class settlement and related fee award, holding that the trial court acted within its discretion and that the settlement and counsel’s representation were adequate despite substantial named-plaintiff opposition.


Parker v. Anderson, 667 F.2d 1204 (5th Cir. 1982), cert. denied, 459 U.S. 828 (1982)