Stahl v. Chen
- Beth Freeman
- 5:25-cv-08679
- U.S. District Court · Northern District of California
- 3
In Stahl v. Chen, Judge Freeman denied Stahl’s motion to represent his children without prejudice because their mother had sole legal custody.
Justin Stahl and the minor plaintiffs, W.S. and C.S.; the motion concerned whether Stahl could represent the children in the lawsuit.
What happened
Justin Stahl v. Cynthia Chen, et al. concerned Justin Stahl’s request to represent his minor children, W.S. and C.S., in the lawsuit. Stahl filed the request without a lawyer and submitted family-court orders after the court asked whether he had authority to make litigation decisions for the children.
The court found that the orders gave the children’s mother sole legal custody, which under California law included responsibility for deciding whether the children should bring a civil lawsuit. The court therefore ruled that Stahl could not represent the children without the mother’s written consent.
Judge A Labson Freeman denied Stahl’s motion without prejudice and ordered him to file a new motion within twenty-one days if he obtained that written consent. The order did not decide the underlying claims in the lawsuit.
The detailed version
- Stahl v. Chen · No. 5:25-cv-08679
- Beth Freeman
- Nov. 21, 2025
Background
Justin Stahl filed a complaint for himself and as the proposed representative for his minor children, W.S. and C.S. He then moved to be appointed as the children’s guardian ad litem, meaning a person appointed to protect and represent a minor’s interests in a lawsuit. Stahl was representing himself without a lawyer.
The court requested more information about whether Stahl had legal authority to make necessary litigation decisions for the children without written consent from another person. Stahl submitted a supplemental declaration and attached family-court orders.
Court’s Analysis
Federal Rule of Civil Procedure 17 provides that a minor who does not have a properly appointed representative may sue through a next friend or guardian ad litem, and that the court must appoint such a representative or issue another appropriate order to protect an unrepresented minor. The rule also provides that a person’s capacity to sue is determined under the law of that person’s domicile.
The court stated that Stahl and the children appeared to be California residents, so California law applied. According to Stahl’s declaration, the family-court orders gave the children’s mother “sole legal custody.” The court explained that California law defines sole legal custody as one parent having the right and responsibility to make decisions about a child’s health, education, and welfare.
The court relied on California authority stating that a parent with the relevant decision-making authority has the right to decide whether and when a child should bring a civil lawsuit. It concluded that Stahl could not serve as the children’s guardian ad litem without the written consent of the person with sole legal custody. The court also stated that it was bound by the family-court custody order while that order remained in force.
Disposition
Judge A Labson Freeman denied Stahl’s Motion for Appointment of Justin Stahl as Guardian Ad Litem for Minor Plaintiffs, ECF No. 11, without prejudice. The order allowed refiling if Stahl obtained the written consent of the person with sole legal custody. It also required Stahl to submit a new motion within twenty-one days of the order, on or before December 12, 2025. The opinion addressed representation of the minor plaintiffs and did not resolve the underlying claims.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.