Guy v. Lorenzen

CourtDistrict Court, S.D. California
DecidedJanuary 11, 2021
Docket3:20-cv-02027
StatusUnknown

This text of Guy v. Lorenzen (Guy v. Lorenzen) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Guy v. Lorenzen, (S.D. Cal. 2021).

Opinion

1 2 3 4 5 6 UNITED STATES DISTRICT COURT 7 SOUTHERN DISTRICT OF CALIFORNIA 8 Case No.: 20cv2027-BAS(BLM) 9 DEOVANTE L. GUY, by and through Guardian

Ad Litem for Deovante Guy, QUINTASIA 10 WALKER, REPORT AND RECOMMENDATION FOR ORDER APPROVING PARTIAL 11 Plaintiff, SETTLEMENT 12 v. 13 MATTHEW LORENZEN, an individual; ANNIE BRADY, an individual; and THE CITY OF SAN 14 DIEGO, a governmental entity, 15 Defendants. 16 17 On November 20, 2020, Plaintiff Deovante L. Guy (“Plaintiff”), by and through his 18 guardian , Defendant Annie Brady (“Defendant Brady”), and Defendants Lorenzen, City 19 of San Diego, and San Diego Police Department filed a Joint Motion for a Determination of Good 20 Faith Settlement. ECF No. 7. The parties explain that Defendant Brady and Plaintiff have agreed 21 to settle this case as to Defendant Brady for a payment of $100,000.00. Id. at 2-3. All of the 22 parties recommend that the Court approve this settlement because the payment constitutes the 23 policy limit of Defendant Brady’s insurance coverage, Defendant Brady does not have the 24 financial ability to contribute further to the settlement, and the settlement is within the “’ballpark’ 25 of Defendant [Brady’s] proportionate liability and was entered into in good faith within the 26 standards set forth in California Code of Civil Procedure § 877.6 and Tech-Bilt v. Woodward- 27 Clyde & Associates, (1958) 38 Cal.3d 488. [sic] Schmid v. Superior Court (1988) 205 Cal.App.3d 1 After reviewing the motion, the Court issued an order requiring supplemental briefing to 2 enable it to perform its duty of evaluating whether the settlement funds were being handled in 3 a fair and reasonable manner to benefit the incompetent plaintiff, Deovante Guy. ECF No. 9; 4 Civ. L.R. 17.1.a. In response, Plaintiff filed a Statement in Support of Approval of Good Faith 5 Settlement with a supporting declaration from the guardian , Quintasia Walker (“GAL 6 Walker”). ECF No. 10. Plaintiff reiterates the previously-stated reasons why the proposed 7 $100,000 settlement is a good faith settlement that should be approved by the Court. Id. at 3. 8 Plaintiff also asserts that the liability against Defendant Brady is “not at all a certainty” and that 9 “the overwhelming responsibility” for Plaintiff’s injuries belong to the other defendants. Id. With 10 regard to the issue of the manner of distribution of the funds, GAL Walker asks the Court to 11 delay making the required determination that the settlement funds are being handled in a fair 12 and reasonable way. ECF No. 10 at 4. Ms. Walker explains that Plaintiff was severely injured 13 by the actions of the defendants, remains “bedridden with severe cognitive defects,” and likely 14 will require extensive future medical treatment, therapy, and care. ECF No. 10-1, Declaration 15 of Quintasia Walker, Guardian Ad Litem for Plaintiff Deovante Guy (“Walker Decl.”), at ¶¶ 2-9. 16 Because the majority of the Plaintiff’s claims remain at issue and because Plaintiff’s damages 17 dramatically exceed the insurance policy limits, Plaintiff asks the Court to defer approval of the 18 distribution of the proposed settlement funds and to authorize the insurance proceeds to be 19 deposited into an “interest bearing trust account or money market account with interest.” Id. 20 at 4. Plaintiff states that after the entire case is resolved, Plaintiff will file a “Petition for Approval 21 and Distribution, supported by Special Needs Trust and Proposed Special Needs Trustee.” Id. 22 Defendants Lorenzen and the City of San Diego (“City Defendants”) filed a response to 23 Plaintiff’s supplemental filing. ECF No. 11. City Defendants reiterate that they support the 24 Court’s finding of good faith under the Tech-Bilt standard based on “Defendant Annie Brady’s 25 stated insurance policy limits and insolvency” and the fact that a “pursuit of a contribution or 26 indemnity claim would be fruitless.” Id. at 1-3. However, City Defendants note that they 27 “adamantly disagree” with Plaintiff’s claims that the “overwhelming responsibility” of Plaintiff’s 1 that they do not waive their rights to “request a setoff against the total recoverable damages or 2 to request that the jury make an apportionment determination (including an allocation as to 3 Defendant Brady) for purposes of awarding damages at trial.” Id. 4 Under California Code of Civil Procedure section 877, “[w]here a release ... is given in 5 good faith before . . . judgment to one or more of a number of tortfeasors claimed to be liable 6 for the same tort, or to one or more other co-obligors mutually subject to contribution rights,” 7 the release shall “reduce the claims against the others in the amount stipulated by the release” 8 and “discharge the party to whom it is given from all liability for any contribution to any other 9 parties.” Cal. Civ. Proc. Code § 877(a), (b). To obtain a determination that it reached a 10 settlement in good faith, “a settling party may give notice of settlement to all parties and to the 11 court, together with an application for determination of good faith settlement.” Id. § 12 877.6(a)(2). Further, a “plaintiff’s claims for damages are not determinative in finding good 13 faith; rather, the court is called upon to make a ‘rough approximation’ of what the plaintiff would 14 actually recover.” West v. Superior Ct., 27 Cal. App. 4th 1625, 1636 (1994) (internal citation 15 omitted). 16 To determine whether a settlement has been made in good faith, the Court considers the 17 factors set out in Tech-Bilt including: (1) a rough approximation of plaintiffs' total recovery and 18 the settlor's proportionate liability; (2) the amount paid in settlement; (3) a recognition that a 19 settlor should pay less in settlement than he would if he were found liable after a trial; (4) the 20 allocation of settlement proceeds among plaintiffs; (5) the settling party's financial condition and 21 the availability of insurance; and (6) evidence of any collusion, fraud or tortious fraud between 22 the settlor and the plaintiffs aimed at requiring the non-settling parties to pay more than their 23 fair share. Tech-Bilt, 38 Cal. 3d at 499; see also Mason & Dixon, 632 F.3d at 1064. The Court's 24 determination must be based on the information available at the time of settlement. Tech-Bilt, 25 38 Cal. 3d at 499. 26 A court must only weigh the Tech–Bilt factors when the good-faith nature of a settlement 27 is disputed. Marine Grp., LLC v. Marine Travelift, Inc., 2013 WL 416407, at *4 (S.D. Cal. Jan.30, 1 absence of a dispute, a “barebones motion which sets forth the ground of good faith, 2 accompanied by a declaration which sets forth a brief background of the case is sufficient.” Id. 3 Here, the Parties filed a joint motion for a determination of a good faith settlement. ECF No. 7. 4 As there is no objection to the good-faith nature of the settlement, the Court does not deem it 5 necessary to engage in a comprehensive Tech-Bilt analysis. The Court notes that City 6 Defendants objected to Plaintiff’s claims that the majority of Plaintiff’s injuries rests with 7 Defendants Lorenzen and the City of San Diego. ECF No. 11 at 1-3. However, City Defendants 8 also stated that it would prove fruitless to pursue a claim for contribution or indemnity from 9 Defendant Brady in light of her insolvency and insurance policy limit. Id. Under California law, 10 when a “‘claimant’s damages are obviously great . . . a disproportionately low settlement figure 11 is often reasonable in the case of a relatively insolvent, and uninsured, or underinsured, joint 12 tortfeasor.’” Fed. Deposit Ins. Corp. v. Dellen, No. CV 10-4915 DSF, 2012 WL 12887408, at *3 13 (C.D. Cal. Oct. 30, 2012) (quoting Tech-Bilt, 38 Cal.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Robidoux v. Rosengren
638 F.3d 1177 (Ninth Circuit, 2011)
Tech-Bilt, Inc. v. Woodward-Clyde & Associates
698 P.2d 159 (California Supreme Court, 1985)
County of Los Angeles v. Guerrero
209 Cal. App. 3d 1149 (California Court of Appeal, 1989)
Zarrahy v. Zarrahy
205 Cal. App. 3d 1 (California Court of Appeal, 1988)
West v. Superior Court
27 Cal. App. 4th 1625 (California Court of Appeal, 1994)
Turner v. Duncan
158 F.3d 449 (Ninth Circuit, 1998)
Smith v. City of Stockton
185 F. Supp. 3d 1242 (E.D. California, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
Guy v. Lorenzen, Counsel Stack Legal Research, https://law.counselstack.com/opinion/guy-v-lorenzen-casd-2021.