Coffey v. County of Alameda

Background

Tariq Coffey sued County of Alameda deputies, asserting federal and state excessive-force claims based on an incident at Santa Rita Jail. In March 2025, Coffey suffered a serious traumatic brain injury unrelated to the lawsuit. The opinion states that the injury rendered him unable to make legal decisions about the case and left him permanently disabled.

The court appointed Jamilah Coffey, Tariq Coffey’s biological sister, as his guardian ad litem. A guardian ad litem is a person appointed to protect and act for someone who cannot make legal decisions in a lawsuit. The parties later reached a settlement in principle at a settlement conference, subject to a written release and court approval because the case involved an incompetent party.

Legal standard

The court explained that it has a special duty to protect the interests of an incompetent person in a proposed civil settlement. It must independently determine whether the settlement serves that person’s best interests. For the federal claims, the court also considered whether the amount that would actually go to Coffey, without considering the portion paid to counsel, was fair and reasonable in light of the claims and comparable cases. The court applied California’s standard for approving settlements involving an incompetent person as well because the case included state-law claims.

The court separately evaluated the requested attorneys’ fees and costs under California law. It considered factors including the value of the legal services, the difficulty of the case, the results obtained, counsel’s experience, the time spent, Coffey’s prior agreement to the fee, the contingent nature of the representation, and the costs advanced by counsel.

Settlement and distribution

The parties agreed to settle the case for $75,000, inclusive of attorneys’ fees and costs. Under Coffey’s contingency-fee agreement, he was to receive 60% of the recovery minus advanced legal costs, while counsel was entitled to 40% of the recovery plus advanced costs. Counsel advanced $819.60 in litigation costs. The resulting net settlement amount for Coffey was $44,180.40.

The court found that amount fair and reasonable. It cited the certainty of recovery, the uncertainty and expense of a jury trial, Coffey’s inability to participate directly after his brain injury, the timing of the settlement before substantial trial expenses accrued, and the consistency of the settlement with other cases in the district involving alleged injuries during in-custody interactions or traffic stops.

The court also approved $30,000 in attorneys’ fees and $819.60 in costs, for a total payment of $30,819.60 to Pointer & Buelna, LLP. The court found the fee reasonable based on the prior agreement, the recovery, more than 50 hours of legal work, counsel’s experience in police-conduct matters, the contingent-fee risk, and the costs counsel advanced.

The court approved the proposed distribution of Coffey’s net recovery. Jamilah Coffey was to receive a one-time $3,000 payment for Coffey’s benefit. The remaining $41,180.40 was to be deposited into an insured, blocked account at a financial institution in California. The account was to make monthly payments of $750 to Jamilah Coffey for Coffey’s benefit until the funds were exhausted.

Ruling

The court granted Coffey’s unopposed motion to approve the settlement and ordered the specified distribution of the settlement funds. This order approved a compromise involving an incompetent litigant; it did not resolve the underlying excessive-force claims on their merits.