R.H. v. Coastal Grove Charter School
- Robert Illman
- 1:25-cv-00826
- U.S. District Court · Northern District of California
- 2
In R.H. v. Coastal Grove Charter School, Judge Illman granted R.H.’s petition and appointed Chris Hatton guardian ad litem.
R.H., a minor, is represented in the case by Chris Hatton, who was appointed guardian ad litem. Coastal Grove Charter School is the defendant.
What happened
R.H. v. Coastal Grove Charter School concerns representation of R.H., a minor, in federal court. Chris Hatton and the school filed a joint petition seeking approval of a minor’s settlement, and R.H. also filed a motion concerning appointment of a guardian ad litem.
The court explained that a minor must be represented by a competent adult and that Federal Rule of Civil Procedure 17(c) allows a court to appoint a guardian ad litem to protect an unrepresented minor. Parents are generally presumed to act in their child’s best interests.
Judge Robert Illman found that Chris Hatton was presumed to act in R.H.’s best interests and that nothing in the record undermined that presumption. The court granted R.H.’s petition for a guardian ad litem and appointed Chris Hatton to that role.
The detailed version
- R.H. v. Coastal Grove Charter School · No. 1:25-cv-00826
- Robert Illman
- Jan. 31, 2025
Background
R.H., a minor, sued Coastal Grove Charter School through a guardian ad litem, an adult appointed to protect and represent a minor’s interests in litigation. The opinion states that, on January 10, 2025, Chris Hatton, identified as R.H.’s proposed guardian ad litem, and the Charter filed a joint petition for approval of a minor’s compromise. The same day, R.H. filed a motion to appoint Tera Palmer as guardian ad litem.
Legal standard
The court relied on Federal Rule of Civil Procedure 17(c). The rule permits a minor to sue through a general guardian, committee, conservator, or similar fiduciary. If a minor does not have an appointed representative, the minor may sue through a next friend or guardian ad litem, and the court must appoint a guardian ad litem or issue another appropriate order to protect the minor. The court also stated that it has broad discretion over guardian ad litem applications and that a parent is generally presumed to act in the child’s best interests.
Ruling
The court found that Chris Hatton, identified in the opinion as R.H.’s father, was presumed to act in R.H.’s best interests and that nothing before the court undermined that presumption. It ordered that R.H.’s petition for a guardian ad litem was GRANTED and appointed Chris Hatton as R.H.’s guardian ad litem.
Disposition
The petition was GRANTED. Chris Hatton was appointed guardian ad litem for R.H.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.