Doe v. Board of Education of Albuquerque Public Schools

District Court, D. New Mexico·Decided September 13, 2022·No. 1:21-cv-01199·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO

Jane Doe, Parent, for A.V., a minor child,

Plaintiff,

v. No. 1:21-cv-01199 LF-SCY

BOARD OF EDUCATION OF ALBUQUERQUE PUBLIC SCHOOLS and DANNY ALDAZ,

Defendants.

ORDER APPROVING SETTLEMENT

THIS MATTER comes before the Court on the parties’ Joint Motion to Approval Settlement Involving Minor Child, filed on June 29, 2022. Doc. 47. The parties stipulated to the appointment of Scott Atkinson to serve as the guardian ad litem (“GAL”) and the Court entered an order approving his service in this capacity on June 13, 2022. Doc. 44. The Court finds that Scott Atkinson is well qualified to act as GAL in this case. Id.; see also Doc. 55 (copy of Scott Atkinson’s resume). On July 5, 2022, the parties consented to me to make a final disposition in this case. Doc. 49. I have carefully reviewed the sealed Guardian Ad Litem Report to the Court (Doc. 53). I conducted a fairness hearing on August 30, 2022, via Zoom. See Doc. 54 (clerk’s minutes). At the hearing, Gail Stewart appeared on behalf of Plaintiff Jane Doe, who also was present. Megan Muirhead appeared for Defendant Albuquerque Public Schools (“APS”). Scott Atkinson appeared in his capacity as the GAL. The Court reviews settlements involving minor children for fairness. See Thompson v. Maxwell Land-Grant and Railway Company, 168 U.S. 451, 463–65 (1897). Before approving such an agreement, the Court must ensure that the interests of the child will be adequately protected. See Garrick v. Weaver, 888 F.2d 687, 693 (10th Cir. 1989) (courts have a general duty to protect the interests of minors); see also United States v. Reilly, 385 F.2d 225, 228 (10th Cir. 1967) (When interests of minors are at stake, the trial judge has an obligation to see that the children were properly

represented by their representatives and by the Court.); Salas v. Brigham, No. 1:08-cv-01184-JB- RLP, 2010 WL 11601205, at *2 (D.N.M. Dec. 22, 2010) (unpublished) (“New Mexico courts and federal courts have traditionally supervised settlements benefitting minors and incapacitated adults, reviewing the proposed settlement to ascertain whether the agreement promotes the best interest of the minor or incapacitated beneficiary.”). The parties and facts of this case are described in more detail in the GAL report (Doc. 53), so the Court need not repeat those details here beyond stating that the case arises out of matters alleged to have occurred during the 2019-2020 school year while the minor was a student at Valle Vista Elementary School. At the fairness hearing on August 30, 2022, the GAL presented his report, and Jane Doe

testified. Counsel also made their presentations and answered questions from the Court. I have considered the evidence and argument presented during the hearing on August 30, 2022. I also have considered the GAL report and the basic terms of the proposed settlement agreement and release. I find that the proposed settlement satisfies the four factors set forth in Jones v. Nuclear Pharmacy, Inc., 741 F.2d 322, 324 (10th Cir. 1984), which the court considers when deciding whether to approve a settlement. These factors are: “(1) whether the proposed settlement was fairly and honestly negotiated; (2) whether serious questions of law and fact exist, placing the ultimate outcome of the litigation in doubt; (3) whether the value of an immediate recovery outweighs the mere possibility of future relief after protracted and expensive litigation; . . . (4) the judgment of the parties that the settlement is fair and reasonable.” Id. I also find that the settlement is in the best interests of the minor child. See Garrick, 888 F.2d at 693. I find that the proposed settlement with Albuquerque Public Schools and the total amount of the settlement were fairly and honestly negotiated during an all-day settlement conference with

retired state court judge Wendy York, an experienced mediator. Jane Doe testified that she understood and participated in the settlement conference, and that she agreed to the final settlement after consulting with her counsel. Jane Doe testified that she believed the settlement was fair and reasonable, that she was not threatened or coerced into agreeing to the settlement, and that she wanted the Court to approve the settlement. She also testified that she understood that the settlement resolves all of A.V.’s claims against APS and its current or former employees related to the matters asserted in the above-captioned lawsuit, and that the funds allocated to the minor child, with the exception of a small amount set aside for the child’s immediate benefit and use, would be placed into a structured annuity. Given these facts, I find that the settlement was honestly and fairly negotiated.

Having heard from the parties and having reviewed the GAL’s report, I also find that serious questions of law and fact place the outcome of this litigation in doubt—including the outcome of the pending criminal matter, and the ability of Jane Doe to establish the elements of her claims against APS. Plaintiff’s First Amended Complaint, filed on April 6, 2022, brought claims against APS for negligence under the New Mexico Tort Claims Act, for violations of Title IX, and for substantive due process violations under 42 U.S.C. § 1983. Doc. 27 at 14–20. Counsel for APS testified at the hearing that they would have raised defenses to the allegations under the New Mexico Tort Claims Act—arguing that window coverings and half walls are not prohibited in classrooms. Had APS been successful with these arguments at trial, the minor child’s recovery could have been substantially reduced. In addition, on April 28, 2022, in Cummings v. Premier Rehab Keller, P.L.L.C., the Supreme Court held that a plaintiff suing under Title IX may not recover emotional distress damages. See 142 S. Ct. 1562. This mid-case change in the law increased the risk for plaintiff that she would recover less at trial than through the settlement. The New Mexico Tort

Claims Act also places a cap on recovery amounts, which also likely would have affected Plaintiff’s recovery at trial. Thus, the Court finds there were serious questions of law and fact that placed the outcome of this litigation in doubt. I further find that the value of an immediate recovery outweighs the mere possibility of future relief after protracted and expensive litigation. Jane Doe testified that a resolution of this matter for the minor child’s mental health and ability to move forward was a motivating factor in the resolution. The GAL also testified that it was in the best interest of the minor child to close this case and move forward. The allocation of the funds also is fair and reasonable. As shown in the GAL report, the minor will receive a small percentage of the overall settlement for participation in extracurricular

activities. Jane Doe testified that she understands these funds may be used only for the minor’s benefit. The funds will be paid as set forth in Exhibit 1, which will be filed under seal as discussed below. The GAL report also reviewed the attorney’s fees that will be paid out of the settlement funds. The fee agreement provides for a percentage of the settlement proceeds which is comparable to or below what typically is charged in other personal injury cases. Ms.

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Doe v. Board of Education of Albuquerque Public Schools, (D.N.M. 2022).

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