FREQUENTLY ASKED QUESTIONS

WHO IS INCLUDED IN THE SETTLEMENT?

You are included in the Settlement if you fall within the following definition:

All current and former hourly employees who worked for FCA US, LLC in the United States any time between February 10, 2020, and May 12, 2025.

WHAT WILL I RECEIVE FROM THE SETTLEMENT?

1.

Defendant will pay $3,795,000.00 as the Gross Settlement Amount. Additionally, Defendant will pay any employer-side payroll taxes related to Individual Settlement Payments. The Gross Settlement Amount will fund all payments to be made under the Settlement.

2.

Out of the Gross Settlement Amount, Defendant will pay to each Class Member who does not submit a valid and timely Request for Exclusion (a “Settlement Class Member”) an amount that is calculated as follows: 

The Settlement Administrator will calculate the total amount that each Settlement Class Member will receive. The Settlement Administrator will divide the Net Settlement Fund by the total number of weeks Settlement Class Members were employed (“Workweeks Amount”) as provided to the Settlement Administrator in the Class Information. The Settlement Administrator will multiply the Workweeks Amount by the total number of weeks that each Settlement Class Member was employed during the Class Period, as provided to the Settlement Administrator in the Class Information, to arrive at an estimated Individual Settlement Amount.

Individual Settlement Amounts will be allocated as follows: 50% as wages subject to withholding; 50% as liquidated damages. The Settlement Administrator will be responsible for issuing a form W-2 for the amount deemed wages and an IRS Form 1099 for the portions allocated to liquidated damages.

3.

The “Net Settlement Amount” means the Gross Settlement Fund, less the Court-approved Class Counsel Award, Class Representative Service Awards, Settlement Administration Costs, and all other Court-approved expenses or disbursements.

4.

Following the Court-approved deductions from the Gross Settlement Amount, the remaining Net Settlement Amount will be paid out entirely to all Settlement Class Members pursuant to the formula set forth in paragraph 2 above. An approximation of your Individual Settlement Payment based on these assumptions appears on your mailed postcard notice. Your actual Individual Settlement Payment may be more or less once awarded.

5.

The Individual Settlement Payments and other amounts awarded by the Court will be paid after final court approval of the Settlement, entry of the final judgment, and the exhaustion of all rights to appeal or review, or after any appeal or review has been resolved in favor of the Settlement.

6.

You will be included in the Settlement and receive your proportional share of the Settlement unless you complete and submit by the deadline of June 22 2026, a Request for Exclusion Form that is provided, HERE, and in accordance with the conditions for submitting that Exclusion. If you do not complete and submit this Form in accordance with the conditions for submitting that Exclusion, you will be bound by this Settlement and receive a Settlement Share.

7.

If ten percent (10%) or more of Settlement Class Members submit a valid Request for Exclusion, Defendant will have the right, but not the obligation, to void the Settlement and the Parties will have no further obligations under the Settlement, including any obligation by Defendant to pay the Gross Settlement Amount. If the actual number of Class Members exceeds the amount of Class Members identified by Defendants to receive notice, 68,000, by five percent (5%) or more, Plaintiffs shall have the sole and absolute discretion to terminate the Settlement unless Defendant agrees to increase the Gross Settlement Fund proportionate to the number of additional individuals in excess of 68,000 based on the additional aggregate weeks worked during the Class Period.

8.

The Court has appointed Atticus Administration, LLC to act as an independent Settlement Administrator and to resolve any dispute concerning the calculation of a Settlement Class Member’s entitlement to an Individual Settlement Payment.

9.

If you dispute the accuracy of any of the information used to calculate your Individual Settlement Payment, shown on your mailed postcard notice, you must ask the Settlement Administrator to resolve the matter. In order to do so, you must contact the Settlement Administrator by the deadline of June 10, 2026, informing the Settlement Administrator of the fact of the dispute and the basis for your contention that different information is correct for you (including any documentary evidence that you have to support your contention).  In the event of such a dispute, Defendant will manually review its payroll and personnel records to verify the correct information. Defendants’ records will have a rebuttable presumption of correctness. After consultation with you, Class Counsel, and Defendant, the Settlement Administrator will make a determination of the correct information, and that determination will be final, binding on you and Defendant, and non-appealable.

10.

The Settlement includes a release of Defendant as named in the Action, and its affiliates and related entities, including, without limitation, their parents and subsidiaries, predecessors, successors, divisions, joint ventures and assigns, clients, and each of their past, present and/or future direct and/or indirect directors, officers, employees, partners, members, investors, principals, agents, insurers, co-insurers, re-insurers, shareholders, administrators, parent companies, subsidiaries, affiliates, divisions, predecessors, successors, assigns, attorneys and personal or legal representatives (“Released Parties”), from any and all claims, rights, causes of action and liabilities, whether known or unknown, for any and all types of relief under the Fair Labor Standards Act, as well as equivalent state laws in Illinois and Ohio, including without limitation claims for failure to pay overtime and any and all claims for recovery of compensation, overtime pay, minimum wage, liquidated damages, interest, and/or penalties tied to such claims, that arose or accrued at any time from February 10, 2020 through May 12, 2025, arising from my employment with FCA US, LLC. (the “Released Claims”).

All settlement checks to Settlement Class Members shall contain, on the back of the check, the following limited endorsement:

PAYEE’S ENDORSEMENT REQUIRED. My signature constitutes consent to join in the Federal Fair Labor Standards Act (“FLSA”) portion of this action and have the Named Plaintiff and her counsel represent me and file a copy of my endorsement/consent with the court in this action pursuant to 29 U.S.C. § 216(b). By signing, I knowingly and voluntarily release, waive, and discharge FCA US, LLC and all other Released Parties, from any and all federal, state, and local wage and hour claims of any nature whatsoever that accrued during my employment with FCA between February 10, 2020 and May 12, 2025, including, but not limited to, all federal, state, and local claims for overtime, minimum wage, and related penalties, interest, liquidated damages, attorneys’ fees, and costs in United States District Court Case Number 23-cv-10362.

11.

Class Representative Service Awards: In addition to their Individual Settlement Payment as Settlement Class Members, the Named Plaintiffs will seek approval from the Court for payment of Class Representative Service Awards in the amount of $10,000.00 for Named Plaintiff Featherstone and $2,500.00 to every other Named Plaintiff (for a total of $32,500.00) for their time and effort in bringing and prosecuting this matter in exchange for the Released Claims.

12.

Class Counsel Attorneys’ Fees and Expenses Payment: Class Counsel has represented and continues to represent the Class on a contingency-fee basis. That means that attorneys’ fees are paid only if money is recovered for the Class. It is common to award attorneys’ fees as a percentage of the Settlement amount negotiated by the attorneys for the Class.  As part of the Final Approval Hearing, Jesse L. Young of Sommers Schwartz, P.C., will request up to $1,265,000.00 for attorneys’ fees (33 1/3% of the Gross Settlement Amount) and up to $25,000.00 for litigation expenses incurred by Class Counsel (Sommers Schwartz, P.C. and Melmed Law Group P.C.) in connection with this case (“Class Counsel Award”). This amount constitutes full and complete compensation for all legal fees, costs and expenses of all Class Counsel, including costs and expenses resulting from experts and other vendors retained by Class Counsel in connection with the litigation and all work done through the completion of the litigation, whatever date that may be.  Class Members will not be required to pay Class Counsel for any other attorneys’ fees, costs or expenses out of their own pockets if the Settlement Agreement and the fee request are finally approved by the Court. Class Counsel’s attorneys’ fees and expenses, as approved by the Court, will be paid out of the Gross Settlement Amount.

13.

Costs of Administration: The reasonable costs of administering the Settlement, including the Settlement Administrator’s fees and expenses, not to exceed $196,000.00, will be paid out of the Gross Settlement Amount.

14.

Deadline to Cash Individual Settlement Payment Checks: Any Individual Settlement Payment checks that are not cashed within one-hundred-eighty (180) calendar days from the date of the mailing of the checks shall be cancelled and said cancellation shall not affect the validity of the Release of claims provided for herein and the Settlement Class Member shall be deemed to, nevertheless, be bound by the Release of claims provided herein. Any uncashed check proceeds will be allocated to the United Way of Michigan.

15.

Plaintiff’s and Class Counsel’s Support of the Settlement: Plaintiff as Class Representative and Class Counsel support the Settlement.  Their reasons include the risk of denial of class certification and a trial on the merits, the inherent delays and uncertainties associated with litigation, and the possibility that the Class is not entitled to any recovery.  Based on their experience litigating similar cases, Class Counsel believes that further proceedings in this case, including a trial and probable appeals, would be very expensive and protracted.  No one can confidently predict how the various legal questions at issue, including the amount of damages, would ultimately be resolved.  Therefore, upon careful consideration of all the facts and circumstances of this case, Class Counsel believe that the Settlement is fair, reasonable, and adequate.

WHAT ARE MY RIGHTS AS A CLASS MEMBER?

Participating in the Settlement

Plaintiff as Class Representative and Class Counsel represent your interests as a Class Member. Unless you elect not to participate in the Settlement, you are a part of the Class, you will be bound by the terms of the Settlement and any final judgment that may be entered by the Court, and you will be deemed to have released the claims against Defendants and the other released parties described above. As a member of the Class, you will not be responsible for the payment of attorneys’ fees or reimbursement of litigation expenses unless you retain your own counsel, in which event you will be responsible for your own attorneys’ fees and expenses.

Objecting to the Settlement

You may object to the terms of the Settlement before final approval. Your objection must be submitted in writing. 

MAIL YOUR OBJECTION TO:

Clerk’s Office
U.S. District Court, Eastern District of Michigan
Theodore Levin U.S. Courthouse
231 W. Lafayette Blvd, Room 599
Detroit, MI 48226

Featherstone v. FCA US
c/o Atticus Administration
PO Box 64053
Saint Paul, MN 55164

CLASS COUNSEL

Jesse L. Young
SOMMERS SCHWARTZ, P.C.
141 E. Michigan Ave., Suite 600
Kalamazoo, Michigan 49007
[email protected]  
DEFENDANTS’ COUNSEL

Jesse R. Dill
OGLETREE DEAKINS
1243 N. 10th Street, Suite 200
Milwaukee, Wisconsin 53205
[email protected]

DO NOT TELEPHONE THE COURT OR DEFENDANTS’ COUNSEL.

Any written objection must contain (1) the name and case number of this Action (or reasonable portion thereof), (2) the full name, last four digits of their social security number, and current address of the Class Member making the Objection, (3) the specific reason(s) for the Objection, and (4) all evidence and supporting papers (including, without limitation, all briefs, written evidence, and declarations) for the Court to consider.

Written objections to the Settlement must be mailed by not later than June 22, 2026.

If you submit a timely written objection, you also may appear or appear through counsel of your choice, paid at your own expense, and be heard at the time of the Final Approval Hearing, if you wish to do so, but only if you indicate in your objection that you intend to appear.

If the Court overrules your objection and you did not submit a timely and valid Request for Exclusion in the Settlement, you will be bound by the terms of the Settlement and receive an Individual Settlement Payment. 

Settlement Class Member Information

The Settlement Class Member Information included in your mailed postcard notice, provides the information on which your Individual Settlement Payment will be calculated and an estimate of your Individual Settlement Payment if all Class Members participate and all payment amounts are awarded; your actual Individual Settlement Payment may be more or less. If the information (including your mailing address) is correct, no further action is needed. If the information is not correct, you must contact the Settlement Administrator. If you believe information is incorrect, state what you contend is the incorrect information and (other than with respect to your name, your address, and the last four digits of your Social Security number) include any documentation you have to support that contention. You must contact the Settlement Administrator and provide the necessary information by no later than June 10, 2026. It is your obligation to keep the Settlement Administrator informed of any changes in your mailing address until your Individual Settlement Payment is received, should Final Approval of the Settlement be granted. Failing to provide the Settlement Administrator with any change of your mailing address may prevent you from receiving your Individual Settlement Payment.

Excluding Yourself from the Settlement

If you do not wish to participate in the Settlement, you must complete the Request for Exclusion available on this website, HERE. The Request for Exclusion must be completed, dated, signed by you, and returned to the Settlement Administrator by not later than June 22, 2026. A Class Member who fails to mail a Request for Exclusion in the manner and by the deadline specified above will be bound by all terms and conditions of the Settlement, and will receive an Individual Settlement Payment, if the Settlement is approved by the Court, and the Judgment if Final, regardless of whether he or she has objected to the Settlement.

Any person who submits a complete and timely Request for Exclusion from the Settlement Administrator will, upon receipt, no longer be a member of the Settlement Class and will not be eligible to receive an Individual Settlement Payment, and he or she will not be included in calculating the Individual Settlement Payment of any other Settlement Class Member. Any such person will retain the right, if any, to pursue at his or her own expense a claim against Defendant. An incomplete or unsigned Request for Exclusion will be deemed invalid.

Consistent with Defendant’s policies, there will be no retaliation or adverse action taken against any Class Member who participates in the Settlement or elects not to participate in the Settlement.

Settlement Administrator’s Address

If applicable, send your corrected Settlement Class Member Information or your Request for Exclusion to the Settlement Administrator at the following address:

Featherstone v. FCA US
c/o Atticus Administration
PO Box 64053
Saint Paul, MN 55164

Phone: 1-800-453-5790
Email: [email protected]

FINAL SETTLEMENT APPROVAL HEARING

The Court will hold a Final Approval Hearing on August 25, 2026, at 2 P.M. EST, in Courtroom 206 of the U.S. District Court for the Eastern District of Michigan, Theodore Levin U.S. Courthouse 231 W. Lafayette Blvd, Detroit, MI 48226, to determine whether the Settlement should be finally approved as fair, reasonable, and adequate. The Court will also be asked to approve the requests for the Class Representative Service Awards and the Class Counsel Award.

The hearing may be postponed without further notice to the Class. It is not necessary for you to appear at this hearing.  If you have submitted an objection and indicated that you intend to appear in the manner set forth above, you may appear at the hearing and be heard.

GETTING MORE INFORMATION

The above is a summary of the basic terms of the Settlement. For the precise terms and conditions of the Settlement, you are referred to the detailed Settlement Agreement, which will be on file with the Clerk of the Court, and which will be available upon request to the Settlement Administrator, or on this website, HERE. The pleadings and other records in this litigation, including the Settlement Agreement, may be examined at the Clerk’s Office, U.S. District Court for the Eastern District of Michigan, Theodore Levin U.S. Courthouse 231 W. Lafayette Blvd, Room 599, Detroit, MI 48226, during the Clerk’s normal business hours; or you may contact Class Counsel or the Settlement Administrator.

PLEASE DO NOT TELEPHONE THE COURT OR DEFENDANTS’ COUNSEL FOR INFORMATION REGARDING THIS SETTLEMENT OR THE CLAIM PROCESS. 

YOU MAY, HOWEVER, CALL THE CLASS COUNSEL LISTED, HERE, OR THE SETTLEMENT ADMINISTRATOR.