O'Neal v. American Shaman Franchise Systems, Inc.
The Eleventh Circuit affirmed the dismissal of a franchisee's fraudulent transfer claims, holding that a settlement agreement barring non-FLSA claims remains enforceable even if the FLSA claims within it lacked required court approval. The court clarified that while the Fair Labor Standards Act mandates judicial or Department of Labor oversight for wage claims, state contract law governs the release of all other claims settled in the same agreement.