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S.D.N.Y.Procedural orderFiled Sept. 4, 2024

Jackson v. Environmental Laboratories, Inc.

Judge
Valerie Caproni
Docket
1:24-cv-03995
Court
U.S. District Court · Southern District of New York
Pages
2
Civil ProcedureClass Action
In one sentence

In Jackson v. Environmental Laboratories, Judge Caproni dismissed the settled case with prejudice, without costs, and without binding absent class members.

Who this affects

The dismissal and any settlement apply only to Sylinia Jackson and Environmental Laboratories Inc.; the order states that they do not bind absent putative class members.

What happened

In Jackson v. Environmental Laboratories, Inc., the parties told the court they had reached an agreement in principle resolving all issues. The plaintiff had sued on behalf of herself and similarly situated people.

The court canceled scheduled conferences and deadlines, dismissed the case with prejudice, ordered that neither party pay costs or attorneys’ fees, and directed the clerk to close the case. The parties could ask to reopen it within 30 days by showing good cause. The court also removed the class-action language from the caption and said the dismissal and settlement would bind only the named plaintiff and the defendant, not absent potential class members.

Judge Valerie Caproni issued the order on September 4, 2024. The court said it could retain jurisdiction to enforce the settlement only if the parties timely submitted the settlement agreement and requested an order retaining that jurisdiction.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Jackson v. Environmental Laboratories, Inc. · No. 1:24-cv-03995
Judge
Valerie Caproni
Date
Sept. 4, 2024

Background

On September 3, 2024, the parties notified the court that they had reached an agreement in principle resolving all issues. The opinion does not describe the underlying claims or the settlement’s terms.

Court’s Order

The court canceled all previously scheduled conferences and other deadlines. It dismissed the case with prejudice and without costs, including attorneys’ fees, to either party. The clerk was directed to terminate all open motions and close the case.

The parties could apply to reopen the case within 30 days of the order. Any application had to show good cause for keeping the case open despite the settlement. The order states that a request filed after 30 days or without a showing of good cause could be denied solely on that basis.

The court also explained that, if the parties wanted the court to retain jurisdiction—the power to enforce the settlement agreement—they had to submit the agreement and request an order expressly retaining jurisdiction within the same 30-day period.

Class Allegations

The clerk was directed to remove from the caption the language stating that the plaintiff sued individually and on behalf of others similarly situated. Because the parties had not told the court that they intended to comply with Federal Rule of Civil Procedure 23(e), which governs court review of certain class settlements and dismissals, the court stated that the dismissal and any settlement would operate only between the individual plaintiff and the defendant. They would not bind absent putative class members.

Disposition

Judge Valerie Caproni dismissed the case with prejudice, without costs to either party, and directed that the case be closed. The order did not decide the underlying claims on their merits.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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