Maldonado v. Crofton

District Court, E.D. California·Decided April 23, 2025·No. 1:24-cv-00991·Unknown

Opinion

1 2 3 4 5 UNITED STATES DISTRICT COURT 6 EASTERN DISTRICT OF CALIFORNIA 7 8 RAFAEL MALDONADO, et al., Case No. 1:24-cv-00991-JLT-CDB

9 Plaintiffs, FINDINGS AND RECOMMENDATIONS TO APPROVE MINOR’S COMPROMISE AND 10 v. TO DIRECT CLERK OF THE COURT TO CLOSE THE CASE 11 STEPHEN ERNEST CROFTON, (Docs. 7, 15, 18) 12 Defendant. 14-DAY DEADLINE 13 14 Plaintiffs Rafael Maldonado, Sarahi Solis, and minor Plaintiff Natalya Maldonado, 15 through guardian ad litem Solis, initiated this action in state court with the filing of a complaint 16 on March 4, 2024, against Defendant Stephen Ernest Crofton. See (Doc. 1 at 2, ¶ 1; Doc. 1-1 at 17 22-28).1 Defendant removed the action to this Court based on diversity jurisdiction on August 18 21, 2024. (Doc. 1). Plaintiffs’ claims relate to personal injuries sustained in connection with 19 their involvement in a traffic collision with a vehicle operated by Defendant. (Doc. 1-1 at 24-25). 20 On November 8, 2024, Plaintiffs filed a notice of settlement representing that all claims 21 among the parties are resolved. (Doc. 5). Upon the Court’s order to timely file dispositional 22 documents (Doc. 6, citing Local Rule 160(b)), Plaintiffs filed a notice of voluntary dismissal on 23 December 4, 2024. (Doc. 7). However, because the claims settled involve a minor, the Court 24 ordered Plaintiffs to file a petition for approval of minor’s compromise as well as proof that the 25 state court that appointed the guardian ad litem had approved of the settlement, consistent with 26 Local Rue 202(b). (Doc. 8). 27 After two extensions of time (Docs. 10, 13), Plaintiffs filed a notice of compliance, 1 attaching the state court order approving the settlement, but without other required 2 documentation. (Doc. 15). The Court ordered Plaintiff to file all supporting documents filed in 3 connection with the state court’s approval of the settlement (Doc. 17); Plaintiffs filed these 4 required documents on March 24, 2025 (Doc. 18). Having considered the state court 5 documentation, the terms of the settlement, and the record of this matter, the undersigned will 6 recommend that the petition for minor’s compromise be approved.2 7 I. Background 8 Plaintiffs’ complaint asserts claims sounding in general negligence based on injuries and 9 property damage they sustained following a collision between Plaintiffs’ passenger sedan and 10 Defendant’s large recreational vehicle. The complaint alleges that, on April 16, 2022, Defendant 11 ran a red light out of exit 20 of the Golden State Highway at an unreasonable rate of speed for the 12 traffic conditions present, making a wide right turn onto the leftmost lane on the eastbound side of 13 Panama Lane, California Highway 99, in Bakersfield, California, sideswiping Plaintiffs’ vehicle 14 on its passenger side, resulting in bodily injuries to Plaintiffs Rafael Maldonado and Sarahi Solis, 15 and damage to the vehicle. (Doc. 1-1 at 24-25). At the time of the collision, Solis was pregnant 16 with minor Plaintiff Natalya Maldonado, yet unborn, who was unharmed. (Doc. 18 at 11, 32). 17 Shortly after commencement of the state court suit, on March 11, 2024, the state court approved 18 the appointment of Solis as guardian ad litem for minor Plaintiff Natalya Maldonado. (Doc. 1-1 19 at 36-37). 20 On March 13, 2025, the state court approved Plaintiffs’ amended petition for minor’s 21 compromise as to Natalya Maldonado, including an amount of $4,999.00, minus attorney’s fees 22 in the amount of $1,249.75 and reimbursement for costs in the amount of $550. (Doc. 18 at 53- 23 56). Accordingly, the proposed settlement funds to be awarded to minor Plaintiff is $3,199.25. 24 (Id. at 55). As part of the settlement, Solis shall receive $1,000,000.00 and Rafael Maldonado 25 shall receive $495,001.00, minus attorney’s fees of 45% each. (Doc. 18 at 12, 16). Accordingly,

26 2 The Court notes that the parties have not filed a stand-alone petition for minor’s compromise and 27 rely entirely on the fully executed agreement and related pleadings in the parallel state court proceeding. As such, the undersigned construes Plaintiffs’ notices with attached state court pleadings as a petition for minor’s compromise. (Docs. 15, 18). 1 the proposed settlement funds to be awarded to Solis and Rafael Maldonado, respectively, are 2 $550,000.00 and $272,250.55. 3 Plaintiffs attached as an exhibit to their state court petition the signed settlement 4 agreement and release, entered into on October 16, 2024. (Id. at 22). The settlement agreement 5 references both the underlying state action and the instant action. (Id.). It provides for awards to 6 each Plaintiff in the same amount as stated in the state court petition. Payment is to be made by 7 check to Plaintiffs’ counsel’s client trust account. (Id. at 23-24, 29). Plaintiffs, Defendant, and 8 Defendant’s insurance providers are to each bear their own attorney’s fees and costs. (Id. at 25). 9 The award to the minor Plaintiff will then be paid to Plaintiff Sarahi Solis, her mother and 10 guardian ad litem. (Id. at 46). 11 As to the reasoning for the apportionment of settlement payments between each Plaintiff, 12 Plaintiffs in their petition provide that the “apportionment of the settlement amounts for each 13 party was based on the medical specials, extent of injuries and overall recovery of each party 14 individually and independent from another.” (Id. at 30). Plaintiff’s counsel declared that the 15 adult Plaintiffs sustained serious injuries in the collision and minor Plaintiff was unharmed, and 16 noted that the case involved formal litigation, discovery, substantial case development, and 17 extensive negotiation. (Id. at 32). 18 Plaintiffs also attached to their petition the operative contingency fee agreement. (Id. at 19 35-38). It sets forth that Plaintiffs pay no initial deposit and that counsel will receive no fee 20 unless there is a financial recovery, with Plaintiffs responsible for all costs and expenses. (Id. at 21 35). The agreement provides for a four-level scale regarding the applicable percentage of 22 attorney’s fees: 1) if settlement before a lawsuit is filed or arbitration demanded, 33.33%; 2) after 23 120 days from the execution of the fee agreement, 40%; 3) if a lawsuit filed, 45%; 4) and if a jury 24 is called, 50%. (Id. at 36). 25 II. Governing Law 26 No settlement or compromise of “a claim by or against a minor or incompetent person” is 27 effective unless it is approved by the Court. Local Rule 202(b). Under Local Rule 202(b)(1), 1 the settlement or compromise shall first be approved by the state court having jurisdiction over the personal representative. Following 2 such approval, a copy of the order and all supporting and opposing documents filed in connection therewith shall be filed in the District 3 Court with a copy to all parties and to the Judge or Magistrate Judge who may either approve the settlement or compromise without 4 hearing or calendar the matter for hearing. 5 Local Rule 202(b)(1). 6 District courts have a special duty to safeguard the interests of litigants who are minors. 7 Federal Rule of Civil Procedure 17(c); Robidoux v. Rosengren, 638 F.3d 1177, 1181 (9th Cir. 8 2011). “The purpose of requiring the court’s approval is to provide an additional level of 9 oversight to ensure that the child’s interests are protected.” K.M. v. Tehachapi School District, 10 No. 1:17-cv-01431-LJO-JLT, 2019 WL 991048, at *4 (E.D. Cal. Feb. 28, 2019). Among other 11 things, a court reviewing a proposed minor’s compromise must “determine whether the net 12 amount distributed to each minor plaintiff in the proposed settlement is fair and reasonable.” 13 Robidoux, 638 F.3d at 1179 (emphasis in original).

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