Gonzalez v. Ahern

Background

Current and former detainees at Santa Rita Jail brought conditions-of-confinement claims under 42 U.S.C. § 1983 against Alameda County, Wellpath, and Aramark. The opinion states that the claims against Wellpath and Aramark had been resolved. The County moved to enforce an oral settlement that plaintiffs’ counsel, Yolanda Huang, allegedly reached on behalf of the individual plaintiffs and a certified class under Federal Rule of Civil Procedure 23(b)(2).

At a May 2024 settlement conference, the case was placed on the record as settled fully against the County, subject to specified terms concerning Aramark. The settlement included injunctive relief and required the County to pay $300,000; Aramark’s payment amount was confidential. The record also stated that Ms. Huang had full authority to settle the County portion and authority over Aramark’s nonmonetary relief, subject to recommending the Aramark monetary settlement to her clients.

A later motion for preliminary approval stated that the County would pay $300,000 for attorney fees and costs and that no class member or named plaintiff would receive money. The attached unsigned agreement released the individual plaintiffs’ and class members’ claims. The County disputed that description and stated that the $300,000 would resolve all issues in the litigation, including attorney fees and costs. The parties could not resolve the disagreement over the settlement language.

Settlement-authority dispute

The court explained that it applies California contract law to determine whether the settlement was formed and interpreted. A settlement must include mutual consent, be complete, and be accepted by the parties or by representatives authorized to bind them. An attorney’s implied authority ordinarily does not extend to surrendering a client’s substantial rights.

Darryl Geyer, who was representing himself, submitted letters expressing concern about the settlement. One letter from Ms. Huang described the injunctive relief but did not mention the County’s $300,000 payment. At a May 22, 2025 hearing, Ms. Huang confirmed that she understood the $300,000 to be only for her attorney fees and costs, with no money going to the individual plaintiffs, and stated that she had authority to release their individual claims for no monetary relief.

Order

The court did not grant or deny the County’s motion to enforce the settlement in this order. Instead, because authority to settle was disputed, the court ordered an evidentiary hearing to determine whether Ms. Huang had authority to enter the settlement and, in particular, to release the individual plaintiffs’ damages claims for no money.

The hearing was set for August 19, 2025, at 10:00 a.m. in Courtroom 8 at 450 Golden Gate Avenue, San Francisco, California. Ms. Huang was ordered to serve the order on the named plaintiffs by May 30, 2025 and file proof of service. If a plaintiff wished to attend, Ms. Huang was directed to arrange that attendance, including by seeking a writ allowing a detained person to testify if necessary. The court expected Ms. Huang and Mr. Geyer to testify, required Ms. Huang to be prepared to provide evidence of authority from each of the 12 plaintiffs, and ordered co-class counsel Thomas Nanney and Richard Brody to appear. Written submissions were due by August 5, 2025, if any party wished to make one.