Allen v. Amazon.com Services LLC

District Court, W.D. Washington·Decided August 15, 2025·No. 2:24-cv-00195·Unknown

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 9 10 CALEB ALLEN et al., CASE NO. 2:24-cv-00195-LK 11 Plaintiffs, ORDER APPROVING MINOR 12 v. SETTLEMENT 13 AMAZON.COM SERVICES, LLC et al., REDACTED 14 Defendants. 15 16 This matter comes before the Court on Plaintiffs’ Unopposed1 Renewed Motion to 17 Approve Minor Settlement. Dkt. No. 48; see also Dkt. No. 46 (redacted version). For the reasons 18 discussed below, the Court grants the motion. 19 I. BACKGROUND 20 A. Factual Background 21 This case concerns injuries A.A., a minor, and his family suffered as a result of an allegedly 22 defective product. Dkt. No. 23 at 2. When A.A. was 16 months old, he was seriously injured after 23 24 1 Defendant Amazon.com Services LLC does not oppose the motion. Defendant Shenzhen Cheyang Technology Co., Ltd. has not yet appeared in this action. 1 he ingested a button battery that fell out of a “Podfofo” brand car stereo remote control that had 2 been purchased from Amazon by the prior owner of his family’s vehicle. Id. at 2, 6. A.A. suffered 3 extreme chemical burns to his esophagus, which required emergency removal and at least one 4 major subsequent corrective surgery. Id. at 2, 8. His parents suffered emotional trauma from having

5 to witness their young child’s suffering. Id. at 8. 6 B. Procedural Background 7 On February 12, 2024, A.A. and his parents filed suit against Amazon. Dkt. No. 1. Roughly 8 six months later, Plaintiffs added the manufacturer of the product, Shenzhen Cheyang Technology, 9 as a Defendant in an amended complaint. Dkt. No. 23. On February 28, 2025, the Plaintiffs and 10 Amazon filed a Joint Notice of Settlement. Dkt. No. 29. The Court subsequently granted Plaintiffs’ 11 petition to appoint attorney Christopher M. Henderson as settlement guardian ad litem (“SGAL”) 12 for minor A.A. pursuant to Federal Rule of Civil Procedure 17. Dkt. Nos. 35, 36. Mr. Henderson 13 filed his SGAL report on July 7, 2025. Dkt. No. 44; see also Dkt. No. 49 (supplement to SGAL 14 report). Plaintiffs then filed their motion to approve the minor settlement on July 18, 2025. Dkt.

15 No. 48. 16 II. DISCUSSION 17 A. Legal Standard 18 Under Rule 17, the Court has a “special duty” to “safeguard the interests of litigants who 19 are minors.” Robidoux v. Rosengren, 638 F.3d 1177, 1181 (9th Cir. 2011); see also LCR 17(c) 20 (requiring that the Court appoint an independent guardian ad litem who is an attorney-at-law in 21 any case involving court approval of a settlement involving the claim of a minor or incompetent). 22 Court-appointed guardian ad litem Christopher M. Henderson has recommended that the Court 23 approve the settlement with the specific distributions described below. See Dkt. No. 44.

24 1 The Court’s inquiry is limited to “the question [of] whether the net amount distributed to 2 minor plaintiff in the settlement is fair and reasonable, in light of the facts of the case, the 3 munor’s specific claim, and recovery in similar cases.” Robidoux, 638 F.3d at 1181-82. This 4 || inquiry must be performed “without regard to the amount received by adult co-plaintiffs and what 5 || they have agreed to pay plaintiffs’ counsel.” Jd. at 1182. “So long as the net recovery to each minor 6 || plaintiff is fair and reasonable in light of their claims and average recovery in similar cases, the 7 || district court should approve the settlement as proposed by the parties.” Jd. 8 || B. The Proposed Settlement 9 The Settlement provides that Amazon (or its insurers) “will pay Plaintiffs a total settlement 10 || consideration of one lump sum payment of a in exchange for the dismissal of this 11 || and all related claims. Dkt. No. 48-1 at 2-3. The settlement amount will be allocated as follows: 12 Amount rete | al 1 AA tino) |] 14 | TheBucheLawFirm |_| 1S See id. at 3-4. 16 The iii allocated to Plaintiffs’ attorneys reflects the terms of their contingency fee 17 agreement, which provides that the attorneys will receive ee | Ec. 2 3. The remaining will go to Plaintiffs. 19 Id. Specifically, aaa will go directly to A.A.’s parents for their pain and suffering as well as 20 “to help offset their considerable outlays.” Jd. $517,304.44 will reimburse The Buche Law Firm 71 for the following advanced fees and expenses: “litigation expenses” of $28,252.67, “SGAL Fees” 22 of $5,362.66,” a “trust drafting fee” of $3,500, and a Medicaid lien of $480,189.11. Dkt. No. 48-1 23 24 > Henderson has graciously requested that payment for his incurred fees of $8.044 be “reduced by 1/3” “to preserve

1 at 4. Finally, A.A. is allocated , which will be placed in a special needs trust managed 2 by a professional trustee and custodian of funds “to invest the amount conservatively so it 3 appreciates prudently while the young boy is growing up and thereafter[.]” Id. at 3–4. 4 Mr. Henderson filed his report on July 7, 2025, recommending that this Court approve the

5 minor settlement. Dkt. No. 44 at 1. Mr. Henderson explains that the proportion allocated to A.A.’s 6 parents appears “appropriate and reasonable” based on his review of similar cases. Id. at 7–8. 7 While Mr. Henderson emphasizes that “[a]ll parties agree that A.A. was by far and away the most 8 impacted Plaintiff as a result of the incident,” A.A. remains “completely dependent on his parents, 9 who continue to make considerable efforts” to obtain the appropriate medical assistance for A.A. 10 given his “young age and comparatively complicated care[.]” Id. at 7–8. Mr. Henderson’s report 11 also finds that the sum allocated to A.A.— —appears fair within the context of 12 other similar cases. Id. at 9. Although confidentiality is often a condition of settlement in such 13 cases and it can therefore “be difficult to determine the value of comparable [settlements],” Mr. 14 Henderson has identified a few similar cases, including a 2014 case with very similar facts (a child

15 sustained serious injuries after ingesting a button battery) that resulted in a final award to the minor 16 child of . Id.; Tarutis, et al. v. Spectrum Brands Holdings, Inc., et al., No. 2:13-cv- 17 00761-JLR, Dkt. No. 51 at 3 (W.D. Wash. May 21, 2015)). On the basis of this and other 18 comparable settlement amounts, Mr. Henderson believes that the net settlement value to A.A. is 19 fair. Dkt. No. 44 at 10. 20 In addition, the settlement amount roughly approximates the costs in medical care A.A. is 21 likely to need over the course of his life. Referencing the Life Care Plan prepared for A.A. by a 22 physician in 2024, Mr. Henderson notes that A.A. is expected to have lifelong physical 23

24 as much as possible for A.A.” Dkt. No. 44 at 15; see also Dkt. No. 42. 1 impairments and disabilities as a result of the incident. Id. at 4. Estimating conservatively and 2 accounting for inflation, Mr. Henderson calculates that, over the next two decades (during which 3 “almost all care is expected to be completed”), the “maximum cost for care anticipated” pursuant 4 to the Life Care Plan is approximately . Id. at 8–9. As such, Mr. Henderson considers

5 A.A.’s settlement allocation adequate under the circumstances. Id. at 10. 6 He further recommends that “the Court order the net settlement proceeds for A.A. be placed in a 7 special needs trust” pursuant to 42 U.S.C. § 1396p(d)(4)(A) and Washington State Superior Court 8 Special Proceeding Rule 98.16W(j)(2)(C). Id. at 2. 9 Lastly, Mr.

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