Paul G. v. Monterey Peninsula Unified School District

Background

Paul G., described in the opinion as a conserved adult, brought the action through his conservator, Steve G. The complaint named Monterey Peninsula Unified School District and the California Department of Education. It alleged violations of Section 504 of the Rehabilitation Act of 1973 and the Americans with Disabilities Act based on the defendants’ alleged failure to provide appropriate educational support during the 2014–2015 and 2015–2016 school years.

The opinion states that Paul has autism and that his disability affects communication, daily living skills, social and emotional functioning, and academic performance. He alleged that the School District knew he needed an intensive applied behavior analysis program but did not provide one. He was later placed on home-hospital instruction when he needed residential treatment, but the District allegedly stopped those services after a few weeks. The opinion also states that no California residential treatment facility would accept him after he turned eighteen and that the State had failed to develop policies or procedures making such services available to disabled students ages eighteen to twenty-two.

The court dismissed the claims against the California Department of Education and entered final judgment for that defendant. Paul appealed, and the United States Court of Appeals for the Ninth Circuit affirmed the dismissal. The district court then lifted its stay of the remaining proceedings. Paul later asked the court to approve his proposed settlement with the School District.

Settlement Terms

The proposed settlement required the School District to pay $35,000 to Paul’s attorney, Ruderman & Knox. The attorney would issue Paul a $25,000 check for deposit into a special-needs trust established by his conservators and would retain $10,000 for attorney fees.

The opinion states that, before the settlement, the School District provided Paul with nearly two years of placement in a residential facility in Kansas. Paul later returned home and participated in an adult transition program until he left special education because of his age. The settlement resolved the remaining dispute concerning the alleged educational harm.

Legal Standard and Ruling

The court explained that Federal Rule of Civil Procedure 17(c) gives a district court a special responsibility to protect a minor or an incompetent person who is not represented in an action. In settlement cases involving a minor’s federal claims, the court must independently examine whether the proposed settlement is fair and reasonable for that person. The court may also apply that approach to state-law claims, and California law requires court approval of settlements involving minors.

The court found that the net amount to be distributed to Paul was fair and reasonable in light of the facts, the claims, and the settlement of the educational-harm dispute. It therefore granted the unopposed motion and approved the settlement on Paul’s behalf. The court ordered the School District to issue the $35,000 check to Ruderman & Knox within 60 days, vacated all future dates and deadlines, and required the parties to file a dismissal stipulation or a written status report by August 15, 2020.

Disposition

The court granted the unopposed motion to approve the proposed settlement. The order did not itself state that the case was dismissed; instead, it required the parties to file a stipulation regarding dismissal or a written status report.