I.W. v. Clovis Unified School District

CourtDistrict Court, E.D. California
DecidedApril 1, 2025
Docket1:24-cv-01074
StatusUnknown

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

Bluebook
I.W. v. Clovis Unified School District, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 I.W., a minor, by and through his mother, Case No. 1:24-cv-01074-JLT-BAM Ruth Aguirre, 12 FINDINGS AND RECOMMENDATIONS Plaintiff, REGARDING PLAINTIFF’S MOTION 13 FOR APPROVAL OF MINOR’S v. COMPROMISE 14 CLOVIS UNIFIED SCHOOL DISTRICT, (Doc. 21) 15 Defendant. ORDER GRANTING JOINT REQUEST 16 FOR STATUS OF MINOR’S COMPROMISE 17 (Doc. 25) 18 19 Findings and Recommendations 20 I. INTRODUCTION 21 I.W., a minor, by and through his mother and guardian ad litem, Ruth Aguirre, requests 22 this court approve the settlement and compromise of I.W.’s claims. The motion is before the 23 undersigned magistrate judge for the issuance of findings and recommendations. (See Doc. 6-1at 24 2.) The Court deemed the motion suitable for decision without oral argument as provided under 25 Local Rule 230(g), and vacated the January 24, 2025 hearing. (Doc. 23.) No opposition or 26 objection to the motion has been filed, and the time in which to do so has passed. However, on 27 March 19, 2025, the parties filed a joint request for status of minor’s compromise. (Doc. 25.) 28 /// 1 Having considered the motion, the terms of the settlement, and the record in this matter, 2 the Court will recommend that the motion for approval of minor’s compromise be granted. The 3 parties’ request for status (Doc. 25) is resolved by the issuance of these findings and 4 recommendations and is therefore GRANTED. 5 II. BACKGROUND 6 On September 11, 2024, Plaintiff I.W. instituted this action by filing a complaint against 7 Defendant Clovis Unified School District (“CUSD”) asserting claims arising under the Americans 8 with Disabilities Act (“ADA”) and Section 504 of the Rehabilitation Act of 1973 (“Section 504”). 9 (Doc. 1.) 10 On September 17, 2024, the Court granted the petition of Ruth Aguirre, Plaintiff’s mother, 11 and appointed her as guardian ad litem. (Doc. 13.) 12 On October 2, 2024, Plaintiff filed a first amended complaint seeking redress under the 13 ADA, Section 504, the Individuals with Disabilities Education Act (“IDEA”), and the California 14 Education Code. The amended complaint included a partial appeal of an administrative decision. 15 (Doc. 15.) 16 On November 27, 2024, Plaintiff filed a motion for preliminary injunction. (Doc. 17.) 17 On December 3, 2024, the parties reached a settlement. (Doc. 21-1, Declaration of 18 Andréa Marcus (“Marcus Decl.”) at ¶ 15; Doc. 21-3, Compromise and Release Agreement 19 (“Agreement”).) 20 On December 5, 2024, CUSD appeared in this action, and Plaintiff filed a notice of 21 settlement pending approval by CUSD’s governing board. (Docs. 18, 19.) Given the notice of 22 settlement, the Court vacated the hearing on the motion for preliminary injunction. (Doc 20.) 23 On December 16, 2024, Plaintiff filed the instant motion for approval of the minor’s 24 compromise. According to the motion, upon the Court’s approval, the Agreement will become 25 final as CUSD’s governing board ratified it on December 13, 2024. (Doc. 21 at 25.) 26 III. LEGAL STANDARD 27 No compromise or settlement of a claim by a minor is effective unless it is approved by 28 the Court. L.R. 202(b). In actions in which the minor is represented by an appointed 1 representative pursuant to appropriate state law, excepting only those actions in which the United 2 States courts have exclusive jurisdiction, the settlement or compromise must first be approved by 3 the state court having jurisdiction over the personal representative. L.R. 202(b)(1). In all other 4 actions, the petition for approval of a proposed settlement or compromise must disclose, among 5 other things, the following:

6 the age and sex of the minor. . . , the nature of the causes of action to be settled or compromised, the facts and circumstances out of which the causes of action arose, 7 including the time, place and persons involved, the manner in which the compromise amount . . . was determined, including such additional information as 8 may be required to enable the Court to determine the fairness of the settlement or compromise, and, if a personal injury claim, the nature and extent of the injury with 9 sufficient particularity to inform the Court whether the injury is temporary or permanent. If reports of physicians or other similar experts have been prepared, 10 such reports shall be provided to the Court . . . . 11 L.R. 202(b)(2). 12 Additionally, when, as here, the minor is represented by an attorney, the representation 13 must be disclosed to the Court, including the terms of employment and whether the attorney 14 became involved in the application at the instance of the party against whom the causes of action 15 are asserted, whether the attorney stands in any relationship to that party, and whether the 16 attorney has received or expects to receive any compensation, from whom, and the amount. L.R. 17 202(c). 18 Federal Rule of Civil Procedure 17(c) also imposes on district courts a special duty to 19 safeguard the interests of litigants who are minors. Robidoux v. Rosengren, 638 F.3d 1177, 1181 20 (9th Cir. 2011). In the context of proposed settlements in suits involving minor plaintiffs, the 21 district court’s special duty requires it to “conduct its own inquiry to determine whether the 22 settlement serves the best interests of the minor.” Id. (quoting Dacanay v. Mendoza, 573 F.2d 23 1075, 1080 (9th Cir. 1978)). In Robidoux, the Ninth Circuit cautioned that this inquiry “requires 24 only that the district court consider whether the net recovery of each minor plaintiff is fair and 25 reasonable, without regard to the amount received by adult co-plaintiffs and what they have 26 agreed to pay plaintiffs’ counsel.” Id. at 1182 (holding that district court erred in denying 27 settlement based solely on the proportion of the settlement going to plaintiffs’ counsel). 28 The district court therefore limits the scope of its review “to the question whether the net amount 1 distributed to each minor plaintiff in the settlement is fair and reasonable, in light of the facts of 2 the case, the minor’s specific claim, and recovery in similar cases.” Id. at 1182-83. 3 Robidoux expressly limited its holding to cases involving settlement of a minor’s federal 4 claims. 638 F.3d at 1179 n.2. Given that the present action is premised on federal question 5 jurisdiction, with the Court exercising supplemental jurisdiction over any state law claims, the 6 Court will apply the Robidoux standard when reviewing the settlement. See Lobaton v. City of 7 San Diego, No. 3:15-cv-1416-GPC-DHB, 2017 WL 2610038, at *2 (S.D. Cal. Jun. 16, 2017) 8 (applying Robidoux to evaluation of minor’s settlement where district court exercising 9 supplemental jurisdiction over state law claims). 10 IV. DISCUSSION 11 A. The Petition Satisfies the Requirements of Local Rule 202 12 1. The Minor 13 According to the moving papers and record, the minor Plaintiff entered the sixth grade on 14 August 25, 2022, as an 11-year-old child. He was born in 2011, making him approximately 13 15 years old. (Doc. 21 at 2; Doc. 21-4 at 1.) Plaintiff has been diagnosed with autism, attention 16 deficit hyperactivity disorder (“ADHD”), and a speech and language impairment. (Doc. 21 at 2.) 17 2. Disclosure of Attorney Interest 18 The moving papers specify that Plaintiff is represented by Andréa Marcus, who was 19 retained by Plaintiff’s mother. (Marcus Decl.” at ¶¶ 3-4; Doc. 21-8, Retainer Agreement.) 20 Counsel’s representation of Plaintiff has been done on a contingency basis. (Marcus Decl. ¶ 5.) 21 Payment of legal fees under the retainer agreement is contingent on the settlement of Plaintiff’s 22 claims, or a court order for attorneys’ fees and costs through prevailing party status. (Doc.

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Related

Robidoux v. Rosengren
638 F.3d 1177 (Ninth Circuit, 2011)
United States v. Martin R. Shields
573 F.2d 18 (Tenth Circuit, 1978)
J. Wilkerson v. B. Wheeler
772 F.3d 834 (Ninth Circuit, 2014)

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Bluebook (online)
I.W. v. Clovis Unified School District, Counsel Stack Legal Research, https://law.counselstack.com/opinion/iw-v-clovis-unified-school-district-caed-2025.