Sylla et al v. Amazon Labor Union et al

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
ANN M. DONNELLY, United States District Judge:
The plaintiffs, 41 members of the Amazon Labor Union (“ALU”), brought this action
against ALU and its then-president for an injunction compelling them to hold a union officer
election pursuant to Sections 101 and 609 of the Labor Management Reporting and Disclosure
Act (“LMRDA”), 29 U.S.C. §§ 411, 529. (ECF No. 9.) After months of litigation and a
settlement conference, the Court entered the parties’ agreed-upon consent order on January 10,
2024. (ECF No. 46.) The parties continued litigation, and in the background, ALU affiliated
with Teamsters and became a new local, ALU-IBT Local 1, under the Teamsters umbrella.
(ECF No. 98-3 ¶¶ 17–19.) ALU-IBT Local 1 held an election in July 2024, and as a result, some
of the plaintiffs became officers of the union. (See ECF Nos. 84, 84-1, 84-2.)
On August 11, 2024, the plaintiffs filed a motion for judgment based on the settlement.
They asked the Court to certify the election, dismiss the case, and set a schedule for a motion for
attorney’s fees. (ECF No. 84.) The Court referred the motion to Magistrate Judge Taryn
A. Merkl on August 26, 2024. (ECF Order dated Aug. 26, 2024.) At a hearing before Judge
Merkl, the plaintiffs said they no longer sought an order certifying the election, but would move
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DR. BRIMA SYLLA, ET AL.,
Plaintiffs,
– against –
AMAZON LABOR UNION AND CHRIS
SMALLS, as President of the Amazon Labor
Union,
Defendants.
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ORDER ADOPTING REPORT
AND RECOMMENDATION
23-CV-5261 (AMD) (TAM)
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to dismiss the case and seek attorney’s fees. (ECF Minute Entry dated Oct. 16, 2024.) The
defendants agreed that the case should be dismissed and opposed the request for attorney’s fees.
(Id.) The plaintiffs filed a consent motion to dismiss the case and to set a deadline for their
motion for attorney’s fees on October 16, 2024, which the Court entered on November 22, 2024.
(ECF Nos. 89-1, 90.) On March 24, 2025, the plaintiffs’ counsel filed a motion for attorney’s
fees. (ECF No. 92.) The defendants opposed the motion. (ECF No. 95.) The Court referred the
motion to Judge Merkl on October 21, 2025. (ECF Order dated Oct. 21, 2025.) On January 26,
2026, Judge Merkl issued a comprehensive Report and Recommendation recommending that the
Court deny the motion, because the requested fee award would shift costs of the litigation to
union members who did not get the benefits of the litigation. (ECF No. 102.) No party has
objected to the Report and Recommendation, and the time for doing so has passed.
A district court deciding whether to adopt a Report and Recommendation “may accept,
reject, or modify, in whole or in part, the findings or recommendations made by the magistrate
judge.” 28 U.S.C. § 636(b)(1)(C). To accept those portions of the Report and Recommendation
to which no timely objection has been made, “a district court need only satisfy itself that there is
no clear error on the face of the record.” Jarvis v. N. Am. Globex Fund, L.P., 823 F. Supp. 2d
161, 163 (E.D.N.Y. 2011) (quoting Wilds v. United Parcel Serv., 262 F. Supp. 2d 163, 169
(S.D.N.Y. 2003)); see also VOX Amplification Ltd. v. Meussdorffer, 50 F. Supp. 3d 355, 369
(E.D.N.Y. 2014). The Court has carefully reviewed Judge Merkl’s well-reasoned Report and
Recommendation for clear error and finds none. Accordingly, the Court adopts the Report and
Recommendation in its entirety and denies the motion for attorney’s fees.
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SO ORDERED.
___________________________
ANN M. DONNELLY
United States District Judge
Dated: Brooklyn, New York
February 11, 2026
s/Ann M. Donnelly
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