Sutton v. California Department of Parks and Recreation

Background

Imani Bey Sutton sued individually and as guardian ad litem for her minor child, L.B., along with Catherine Cosby. The defendants included the California Department of Parks and Recreation, several park rangers, Friends of Santa Cruz State Parks, and Donna Walizer. The park-ranger defendants were later dismissed, leaving Friends, Walizer, and the Department as the remaining defendants.

The plaintiffs alleged that, during a picnic at Seacliff State Beach on or about March 27, 2021, Walizer mistakenly reported that they intended to shoot law enforcement if officers arrived. According to the allegations, park rangers responded with guns drawn and detained the plaintiffs while investigating. The plaintiffs brought federal and state civil-rights claims and negligence claims.

The remaining defendants agreed to settle the suit for a collective $225,000. Friends and Walizer agreed to settle all of the plaintiffs’ claims for $200,000. L.B., through her guardian ad litem, agreed to settle all claims against the Department for $25,000 and separately agreed to dismiss the claims against the individual park rangers.

Legal standard

Federal Rule of Civil Procedure 17(c) requires a district court to protect the interests of minor litigants. For a proposed settlement involving a minor, the court independently evaluates whether the settlement is in the minor’s best interests. Under the standard applied by the court, the main inquiry is whether the minor’s net recovery is fair and reasonable in light of the facts, the minor’s claims, and recoveries in similar cases.

The court applied this standard to both L.B.’s federal and state claims. It also approved using a blocked account, meaning an account from which money cannot be withdrawn without a court order, to protect the settlement funds until L.B. reaches adulthood.

Court’s analysis and ruling

The proposed distribution of the $225,000 settlement was:

- $75,000 to Attorney Eric John Nelson for attorney fees and costs; - $30,000 to L.B.; - $70,000 to Imani Bey Sutton; and - $50,000 to Catherine Cosby.

The court found L.B.’s $30,000 net recovery fair and reasonable. It noted that the attorney fees and costs were addressed separately, so L.B. would receive the full $30,000 allocated to her.

The court granted L.B.’s Motion to Approve Minor’s Compromise. The order approved payment of $25,000 by the State of California and $200,000 on behalf of Friends of Santa Cruz State Parks and Donna Walizer. After the $75,000 in attorney fees and costs, the remaining $150,000 must be distributed as follows: $30,000 to L.B., $70,000 to Imani Bey Sutton, and $50,000 to Catherine Cosby.

L.B.’s $30,000 must be deposited into an interest-bearing, federally insured blocked account in the name of Imani Bey Sutton as guardian ad litem for L.B. The funds, including interest, cannot be withdrawn without a written court order signed by a judicial officer and filed with the court until L.B. reaches 18. At that time, the depository may pay the funds directly to L.B. without another court order. The parties must file a joint dismissal stipulation or a settlement status report by August 22, 2025.