Mental Health & Wellness Coalition v. Stanford University

Background

The parties jointly reported that they had resolved all outstanding issues and executed a written settlement agreement. Because the case involved proposed class claims that had not yet been certified, the court requested additional briefing about possible prejudice to absent members of the proposed class. The court asked about possible reliance on publicity about the case, whether a rapidly approaching limitations period could leave class members without enough time to bring other actions, and whether the class representative or counsel had compromised class interests for their own benefit.

Settlement review

The parties filed supplemental briefing and publicly filed the full settlement agreement, which the court reviewed. The court also reviewed the disclosure of attorney fees paid to plaintiffs' counsel and found the amount reasonable for the services provided. The court noted that a mediator facilitated the settlement through multiple in-person sessions and telephone calls, which suggested that the agreement was not the product of improper cooperation between the parties. The court also found that publicity about the case was limited and accurately communicated the settlement terms, reducing possible prejudice to absent proposed-class members.

Ruling

The court approved the settlement under the “lighter form” of Federal Rule of Civil Procedure 23(e), which applies in this circuit to class claims before a class is certified. The agreement resolved all individual claims asserted by the seven named plaintiffs and resolved issues concerning attorney fees and costs. It did not release the claims of unnamed members of the proposed class and did not provide for certification of a settlement class.

Judge Nathanael M. Cousins dismissed the action. The dismissal was with prejudice solely as to the named plaintiffs—Mental Health & Wellness Coalition, Erik X., Tina Y., Jacob Z., Harrison Fowler, Rose A., and Sofia B.—and without prejudice as to all unnamed members of the proposed class. The court retained jurisdiction over the parties for two years to enforce the settlement agreement, and the clerk was ordered to terminate the case.