Sifuentes v. X Corp.
- Sallie Kim
- 3:24-cv-00590
- U.S. District Court · Northern District of California
- 3
In Sifuentes v. X Corp., Judge Corl denied Sifuentes’s motion to withdraw consent to magistrate-judge jurisdiction after judgment was entered.
The ruling directly affected David Angel Sifuentes’s request to withdraw consent to magistrate-judge jurisdiction; it denied that request in the case against X Corp., Inc.
What happened
In David Angel Sifuentes v. X Corp., Inc., Sifuentes, who represented himself, had consented to proceedings before Magistrate Judge Sallie Kim, as had X Corp., Inc. Judge Kim later entered judgment for X Corp., Inc. on all claims.
After judgment, Sifuentes asked to withdraw his consent and have the case reassigned to a district judge. He argued that he could withdraw consent at any time, but he did not claim extraordinary circumstances or show good cause for withdrawing consent.
Judge Jacqueline Scott Corl denied the motion. The court held that, after all parties consented, withdrawal required extraordinary circumstances or at least good cause, and Sifuentes had shown neither.
The detailed version
- Sifuentes v. X Corp. · No. 3:24-cv-00590
- Sallie Kim
- Feb. 3, 2025
Background
David Angel Sifuentes, III, represented himself in this action against X Corp., Inc. The case was assigned to Magistrate Judge Sallie Kim, and Sifuentes consented to magistrate-judge jurisdiction. X Corp., Inc. later also consented. Judge Kim issued rulings in the case, including granting X Corp., Inc.’s motion to dismiss the Second Amended Complaint without leave to amend on all claims except intentional infliction of emotional distress. After Sifuentes amended that claim, Judge Kim dismissed it without leave to amend and entered judgment for X Corp., Inc. on all causes of action.
After judgment, Sifuentes moved for reconsideration and to alter or amend the judgment. He also moved for the first time to withdraw his consent to magistrate-judge jurisdiction and requested reassignment to an Article III district judge. Because a district judge must decide a motion to withdraw consent, the motion was assigned to Judge Jacqueline Scott Corl.
Court’s Analysis
The court explained that once all parties consent to magistrate-judge jurisdiction, consent may be withdrawn only for good cause shown on the court’s own motion or when a party shows extraordinary circumstances. There is no absolute right in a civil case to withdraw consent to trial and other proceedings before a magistrate judge.
Sifuentes did not argue that extraordinary circumstances existed. Instead, he argued that he could withdraw consent at any time without showing cause. The court found that the authority he cited concerned a different situation: withdrawal before any other party had consented. Here, all parties had consented before Sifuentes sought withdrawal, and Judge Kim had already entered judgment.
Ruling
Judge Corl found that Sifuentes was required to show extraordinary circumstances or at least good cause and had not done so. The court also stated that he could not do so. The motion to withdraw consent to magistrate-judge jurisdiction was DENIED. The order disposed of Docket No. 86.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.