L.J. v. Amazon.com,Inc.

CourtDistrict Court, S.D. California
DecidedDecember 12, 2024
Docket3:23-cv-01662
StatusUnknown

This text of L.J. v. Amazon.com,Inc. (L.J. v. Amazon.com,Inc.) 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
L.J. v. Amazon.com,Inc., (S.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 9 10 UNITED STATES DISTRICT COURT 11 SOUTHERN DISTRICT OF CALIFORNIA 12 13 L.J., a minor, by and through her guardian Case No.: 23-cv-01662-TWR-JLB ad litem, Rhianna Johnson, et al., 14 [REDACTED] Plaintiffs, 15 v. REPORT AND 16 RECOMMENDATION RE: JOINT AMAZON.COM, INC., 17 MOTION FOR REVIEW AND Defendant. APPROVAL OF MINOR’S 18 COMPROMISE 19 [ECF Nos. 34; 36] 20 21 22 Before the Court is the parties’ Joint Motion for Review and Approval of Minor’s 23 Compromise (“Motion for Approval”). (ECF Nos. 34 (public); 36 (sealed).) The Court 24 ordered supplemental briefing, which Plaintiffs submitted on October 15, 2024. (ECF No. 25 42.) This Report and Recommendation is submitted to the Honorable Todd W. Robinson, 26 United States District Judge, pursuant to 28 U.S.C. § 636(b)(1) and Local Civil Rule 17.1 27 of the United States District Court for the Southern District of California. After reviewing 28 the Motion for Approval and all supporting documents, and for the reasons discussed 1 below, the Court RECOMMENDS that Judge Robinson GRANT the Motion for 2 Approval as set forth below. 3 I. BACKGROUND 4 Plaintiff L.J. is a minor appearing by and through her court appointed guardians ad 5 litem, Rhianna Johnson and Nick Johnson. (ECF No. 1.) According to the allegations in 6 the Complaint, on July 25, 2021, eleven-year-old L.J. used the “Morovan Acrylic Nail Kit 7 with Everything – for beginners Nail Supplies, Gel Nail Polish Kit with UV Light 6W, 8 Glitter Acrylic Powder Monomer UV Gel Acrylic Nails Extension Nail Art Starter Kit” (the 9 “Product”) relying on advertising and reviews that it was safe and for beginners. (Id. at 10 13–14, 22.) L.J. sustained severe exothermic chemical burns to her buttocks region when 11 the Nail Glue included in the defective product, which contained a powerful adhesive 12 known as “cyanoacrylate,” spilled onto her thighs, pooling underneath her buttocks and 13 interacting with her bathing suit bottoms. (Id. at 10.) She endured excruciating pain and 14 received emergency treatment, including undergoing multiple surgical procedures. (Id. at 15 22, 24–25.) While her wounds have healed, L.J. has substantial visible scarring and 16 sensitivity. (Id. at 24–25.) She continues to suffer from the emotional trauma of the 17 incident. (Id.) 18 On July 14, 2023, Plaintiffs commenced this action against Defendant Amazon.com, 19 Inc. (“Amazon”) in California Superior Court alleging negligent product liability, strict 20 liability, and negligent infliction of emotional distress. (Id. at 9–33.) On 21 September 8, 2023, Defendant Amazon removed the action to federal court on the basis of 22 diversity jurisdiction. (ECF No. 1 at 1–6.) The undersigned judge held an Early Neutral 23 Evaluation and Case Management Conference on November 9, 2023. (ECF No. 11.) The 24 case did not settle, and a scheduling order was issued. (Id.; ECF No. 12.) On 25 June 24, 2024, the parties filed a Notice of Settlement in Principle, informing the Court 26 that they were in the process of drafting and executing the formal settlement agreement, 27 minor’s compromise, and related dismissal papers. (ECF No. 23.) On September 17, 2024, 28 the parties filed a Joint Motion for Review and Approval of Minor’s Compromise. (ECF 1 Nos. 34; 36.) A Declaration by attorney Elliot Jung in support of the Motion for Approval 2 was included. (ECF Nos. 34-2 at 1–6; 36 at 10–15.) Plaintiffs’ counsel submitted a 3 Supplemental Pleading In Support of Joint Motion for Review and Approval of Minor’s 4 Compromise (“Supplemental Brief”) on October 15, 2024. (ECF No. 42.) The 5 Supplemental Brief included another Declaration by Elliot Jung (“Jung Declaration”) in 6 support of the Motion for Approval. (ECF No. 42-1 at 1–6.) A Hearing on the Motion for 7 Approval was held before the undersigned judge on November 7, 2024. (ECF No. 45.) 8 II. LEGAL STANDARD 9 District courts have “a special duty, derived from Federal Rule of Civil Procedure 10 17(c), to safeguard the interests of litigants who are minors.” Robidoux v. Rosengren, 638 11 F.3d 1177, 1181 (9th Cir. 2011) (citing Fed. R. Civ. P. 17(c)(2) (“The court must appoint 12 guardian ad litem—or issue another appropriate order—to protect a minor or incompetent 13 person who is unrepresented in an action.”)). “In the context of proposed settlements in 14 suits involving minor plaintiffs, this special duty requires a district court to ‘conduct its 15 own inquiry to determine whether the settlement serves the best interests of the minor.’” 16 Robidoux, 638 F.3d at 1181 (quoting Dacanay v. Mendoza, 573 F.2d 1075, 1080 (9th Cir. 17 1978)); see also Salmeron v. United States, 724 F.2d 1357, 1363 (9th Cir. 1983) (“[A] court 18 must independently investigate and evaluate any compromise or settlement of a minor’s 19 claims to assure itself that the minor’s interests are protected, even if the settlement has 20 been recommended or negotiated by the minor’s parent or guardian ad litem.”) (citation 21 omitted). 22 Local Rule 17.1 mandates that “[n]o action by or on behalf of a minor or 23 incompetent, or in which a minor or incompetent has an interest, will be settled, 24 compromised, voluntarily discontinued, dismissed or terminated without court order or 25 judgment.” CivLR 17.1.a. The court is required to determine whether the settlement is in 26 the best interests of the minor, considering not only the fairness of the settlement, but also 27 the structure and manner of the plan for the payment and distribution of the assets for the 28 benefit of the minor. See CivLR 17.1.b. 1 In the Ninth Circuit, courts reviewing the settlement of a minor’s federal claims 2 should “limit the scope of their review to the question whether the net amount distributed 3 to each minor plaintiff in the settlement is fair and reasonable, in light of the facts of the 4 case, the minor’s specific claim, and recovery in similar cases.” Robidoux, 638 F.3d at 5 1181–82. Courts should “evaluate the fairness of each minor plaintiff’s net recovery 6 without regard to the proportion of the total settlement value designated for . . . plaintiffs’ 7 counsel—whose interests the district court has no special duty to safeguard.” Id. at 1182 8 (citing Dacanay, 573 F.2d at 1078). “So long as the net recovery to each minor plaintiff is 9 fair and reasonable in light of their claims and average recovery in similar cases, the district 10 court should approve the settlement as proposed by the parties.” Robidoux, 638 F.3d at 11 1182. 12 “In considering the fairness of a minor’s state law settlement, federal courts 13 generally require that claims by minors . . . be settled in accordance with the applicable 14 state law.” Lobaton v. City of San Diego, No. 3:15-cv-1416-GPC-DHB, 2017 WL 15 2610038, at *2 (S.D. Cal. June 16, 2017) (internal quotation marks and citation omitted). 16 California law requires court approval of a settlement for a minor and attorney’s fees to 17 represent a minor. Cal. Prob. Code § 3601; Cal. Fam. Code § 6602. Under California state 18 law, the Court is tasked with evaluating the reasonableness of the settlement and 19 determining whether it is in the best interest of the minor. Espericueta v. Shewry, 164 Cal. 20 App. 4th 615, 619-20 (2008).

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Related

Robidoux v. Rosengren
638 F.3d 1177 (Ninth Circuit, 2011)
Norman v. Hall
136 P. 720 (California Court of Appeal, 1913)
In Re Estate of Donnellan
127 P. 166 (California Supreme Court, 1912)
People v. Price
8 Cal. App. 5th 409 (California Court of Appeal, 2017)
Serbin v. Ziebart International Corp.
11 F.3d 1163 (Third Circuit, 1993)
Salmeron v. United States
724 F.2d 1357 (Ninth Circuit, 1983)

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L.J. v. Amazon.com,Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/lj-v-amazoncominc-casd-2024.