Adams v. Enplas USA, Inc., No. 1:25-CV-03882-SDG, 2026 WL 2908745 (N.D. Ga. Sept. 28, 2026)

Employees sometimes sign broad release agreements when resolving workplace disputes, including workers’ compensation matters. But a recent federal decision from Georgia highlights an important limitation: an employer generally cannot use a private release agreement to waive an employee’s claim for unpaid overtime under the Fair Labor Standards Act (FLSA).

In Adams v. Enplas USA, Inc., the court held that a broad release barred the former employee’s discrimination and retaliation claims, but it did not eliminate his claim that the employer failed to pay overtime. The decision is a practical reminder that FLSA wage rights receive special protection—even where an employee has signed an agreement releasing other employment-related claims.

The Case Background

Deleslie Adams sued his former employer, Enplas USA, Inc., alleging discrimination and retaliation under Title VII and 42 U.S.C. § 1981, along with violations of the FLSA.

Adams alleged that he worked at least one instance of overtime for which he was not paid and that Enplas engaged in a pattern of coercing him to work overtime without proper compensation.

Before Adams filed suit, the parties had entered into a release agreement in connection with a workers’ compensation matter.

Enplas argued that the release barred every claim in the lawsuit and sought summary judgment—a ruling without a trial.

A magistrate judge recommended dismissing all of Adams’s claims based on the release, but Adams objected.

This distinction was critical because, although parties can often settle and release many employment claims by contract, FLSA wage-and-hour claims are governed by different rules.

The Legal Issues Before the Court

The federal district court addressed two separate questions:

• Whether the release covered Adams’s discrimination and retaliation claims; and
• Whether the same private release could legally eliminate his FLSA unpaid-overtime claim.

What Did the Release Say?

The agreement stated that Adams released Enplas from “any and all” actions, causes of action, damages, and claims of every kind arising from an alleged accident or injury during his employment.

Adams argued that, because the agreement was connected to a workers’ compensation settlement, “accident or injury” should be understood as referring only to physical injuries.

The court disagreed as to the discrimination and retaliation claims, finding that the release’s language was broad, clear, and not limited to workers’ compensation claims or physical injuries.

In other words, the agreement’s broad wording was enough to release those non-FLSA claims.

Why the Overtime Claim Was Different

The court reached the opposite result on Adams’s unpaid-overtime claim.

Under controlling Eleventh Circuit law, employees and employers generally cannot privately settle or waive FLSA overtime claims through an ordinary release agreement.

The court explained that there are only two recognized paths for resolving an FLSA overtime claim:

1. The U.S. Department of Labor supervises the payment of unpaid wages; or
2. In an employee-filed lawsuit, the parties present a proposed settlement to a court, and the court approves it as a fair resolution of a genuine dispute.

There was no evidence that the Department of Labor supervised payment of Adams’s claimed overtime wages or that a court reviewed and approved the release as an FLSA settlement.

For that reason, the court concluded that the private release could not waive Adams’s FLSA overtime rights.

The Court’s Decision

The court granted Enplas summary judgment on Adams’s discrimination and retaliation claims because those claims were covered by the release.

Those claims were dismissed with prejudice, meaning Adams cannot bring them again.

However, the court denied Enplas’s request for summary judgment on the FLSA overtime claim, allowing that claim to proceed.

The ruling did not determine whether Adams is ultimately entitled to unpaid overtime; it decided only that the release agreement did not end his right to pursue that claim.

What This Decision Means for Employees

For workers, Adams reinforces that signing a broad release does not necessarily end every wage-and-hour claim.

Employees should keep the following points in mind:

• A severance, settlement, workers’ compensation, or general release agreement may waive many claims, including discrimination and retaliation claims, depending on its language.
• An unpaid-overtime claim under the FLSA is different because it ordinarily cannot be privately waived or settled without Department of Labor supervision or court approval.
• A release agreement should be reviewed carefully before signing, particularly when the employee believes they worked off the clock, worked more than 40 hours in a workweek, or were not paid overtime properly. The case materials reflect an allegation that Adams was required to work overtime without proper payment.

What Employers Should Take Away

For employers, the decision serves as a warning against relying on generic release language to eliminate potential FLSA overtime liability.

Even a release written in sweeping terms—covering “any and all” claims—may not be enforceable as to unpaid overtime under the FLSA.

Employers addressing potential overtime disputes should consider whether the proposed resolution follows one of the legally recognized methods identified by the court: Department of Labor-supervised payment or a court-reviewed settlement in an employee-filed case.

Bottom Line

The Adams decision draws a clear line between general employment claims and FLSA overtime claims. A carefully drafted private release may bar discrimination and retaliation claims, as it did here, but it cannot by itself erase an employee’s right to seek unpaid overtime under the FLSA.

If you believe you were denied overtime pay, required to work off the clock, or asked to sign a release involving wage claims, preserve your pay records, schedules, timekeeping communications, and the agreement itself. The materials in Adams show why the specific type of claim—and the process used to resolve it—can be just as important as the wording of the release.

Click Adams v. Enplas USA, Inc. to read the entire Order.