Johnson v. Camden Almaden, LLC

Background

On February 4, 2021, the parties filed a joint stipulation under Federal Rule of Civil Procedure 41(a)(1)(A)(ii). They agreed that the action could be dismissed with prejudice as to all parties, that each party would pay its own attorneys’ fees and costs, and that the matter had been resolved to everyone’s satisfaction. Under that rule, the plaintiff dismissed the action without a court order, and the Clerk of Court terminated and closed the case.

The stipulation did not expressly reserve the court’s jurisdiction over the settlement and did not incorporate the settlement’s terms into an order of dismissal. On May 19, 2021, Johnson filed an ex parte application for entry of stipulated judgment, asking the court to enforce the settlement based on an alleged breach by Camden Almaden.

Court’s Analysis

The court held that it lacked subject-matter jurisdiction, meaning authority to decide the application. It explained that a federal court has ancillary jurisdiction—limited authority connected to an existing case—to enforce a settlement only when the parties’ obligation to comply with the settlement has been made part of the dismissal order. That can occur through an express provision retaining jurisdiction or by incorporating the settlement’s terms into the order.

Here, the Clerk’s termination of the case followed the parties’ stipulation, which only stated that the matter had been resolved to their satisfaction. The court had not stated that it intended to retain jurisdiction, and no dismissal order expressly retained jurisdiction or incorporated the settlement’s terms.

Disposition

Judge Lucy Koh DENIED for lack of jurisdiction Johnson’s ex parte application for entry of stipulated judgment. The opinion did not determine whether Camden Almaden breached the settlement agreement.