Hamilton v. K-D-W Santa Clara

Background

Jeneen Hamilton and her daughter, Faith Hamilton, a minor, brought an action alleging violations of Title III of the Americans with Disabilities Act and California’s Unruh Civil Rights Act. They alleged that architectural barriers in the women’s restroom at a Fish Market restaurant in Santa Clara, California, prevented Faith from having full and equal access. According to the complaint, they used the men’s restroom, which caused embarrassment, and plaintiffs were deterred from returning because the women’s restroom was not accessible.

The parties reported reaching a settlement and sought court approval of the settlement of Faith’s claims. The court had previously found discrepancies and insufficient information in the original motion. The amended motion was unopposed.

Settlement Terms

The parties did not provide the underlying settlement agreement. They stated, however, that defendants agreed to provide an accessible women’s restroom at the restaurant by June 2022. Until then, defendants would use a written policy and signage to permit people with disabilities to use the men’s restroom.

The total monetary settlement was $25,000: $4,500 for Faith Hamilton, $8,500 for Jeneen Hamilton, and $12,000 for plaintiffs’ counsel for fees and costs. Faith’s share would be distributed to Jeneen, who stated that the money would be used for Faith’s benefit, including ongoing physical therapy and other immediate and recurring health expenses. Counsel stated that the fees and costs incurred totaled $10,403 and that the settlement reduced the additional amount counsel otherwise would have received under the fee agreement.

Court’s Analysis

Under Federal Rule of Civil Procedure 17(c), courts have a special duty to protect minors who are parties to litigation. For a proposed settlement involving a minor’s federal claims, the court must independently determine whether the settlement serves the minor’s best interests. The court focuses on the minor’s net recovery and whether that recovery is fair and reasonable in light of the case’s facts, the minor’s claims, and similar settlements. The court does not compare the minor’s recovery with amounts allocated to adult co-plaintiffs or counsel.

The court noted that Faith’s $4,500 allocation exceeded the $4,000 minimum statutory damages available under the Unruh Act for each occasion on which an individual is denied equal access to a covered establishment. Although plaintiffs did not cite recoveries from similar cases, the court found that Faith’s proposed recovery was comparable to or greater than recoveries in analogous civil-rights matters.

Disposition

The court granted plaintiffs’ unopposed amended motion for approval of the minor’s compromise. It reset the deadline for filing a stipulated dismissal to June 30, 2020. If no dismissal was filed by that date, the parties were required to file a status report by July 2, 2020, and appear on July 7, 2020, to show cause why the case should not be dismissed under Federal Rule of Civil Procedure 41(a).