F.R. v. Santa Clara Unified School District

Background

F.R., a minor represented by her mother, Mila Romero, acting as guardian ad litem, alleged that staff at the public school she attended for kindergarten mistreated and sexually battered her. The first amended complaint asserted federal and state claims against three teachers, the school principal, and the Santa Clara Unified School District.

After a settlement conference with Magistrate Judge Virginia K. DeMarchi, the parties reached a settlement that was subject to approval by the District’s Joint Powers Authority’s Executive Committee. The written agreement provided that F.R. would dismiss her claims against all defendants with prejudice in exchange for $20,000. The parties would bear their own costs and attorneys’ fees. F.R.’s counsel waived their fees and gave up reimbursement of nearly $5,000 in advanced costs, so the full $20,000 would go to F.R.

Approval of the Minor’s Settlement

The court explained that Federal Rule of Civil Procedure 17(c) gives district courts a special duty to protect minors’ interests. When a minor’s case settles, the court must independently determine whether the settlement is in the minor’s best interests. The court applied this standard to both F.R.’s federal and state claims.

The court found the settlement fair and reasonable. It noted that the claims were extremely serious but could be difficult to prove because of F.R.’s young age when the events occurred and the apparent lack of witnesses to the alleged abuse.

Romero asked for permission to use $4,800 of the settlement for 20 occupational-therapy sessions at $240 per session. She described F.R.’s emotional distress and difficulties with fine motor skills, potty training, focus, and socializing. The court found this explanation sufficiently detailed and supported the requested expenditure.

The court approved the proposed arrangement under which the $20,000 would be deposited into an interest-bearing blocked account in F.R.’s name. No withdrawals would be allowed until F.R. turns 18 unless the court orders otherwise, and Romero was authorized to withdraw $4,800 for F.R.’s occupational therapy. The court granted the petition for approval of the minor’s compromise.

Motion to Seal

F.R. also filed an unopposed administrative motion to seal the proposed order because it contained her full name. A redacted version using the initials F.R. had already been placed on the public docket.

The court applied the “compelling reasons” standard for sealing because the proposed order was more than tangentially related to the case’s merits and its issuance would terminate the case. The court found compelling reasons to protect F.R.’s full name, including the federal rules’ protection for minors’ names and F.R.’s strong privacy interest given the nature of her allegations.

The court granted the sealing motion. The version containing F.R.’s full name is to be filed under seal, while a redacted version remains on the public docket.

Disposition

Judge Beth Labson Freeman vacated the hearing previously set for January 2, 2025, granted the petition for approval of the minor’s compromise, and granted F.R.’s administrative motion to seal. The order terminated docket entries ECF 61 and ECF 62.