Johnson v. Chatha

Background

Scott Johnson filed this action in December 2018 under the Americans with Disabilities Act and the Unruh Civil Rights Act. He sought damages and an order requiring relief, and the complaint alleged one or more architectural barriers. In September 2019, the parties stipulated to dismissal under Federal Rule of Civil Procedure 41(a)(1)(ii). The settlement apparently required monthly installment payments.

Johnson stated that a defendant stopped making payments in February 2021. On May 11, 2021, he filed an ex parte application—an application made without the usual advance participation of the opposing party—for entry of a judgment based on the parties’ stipulation.

Court’s analysis

The court explained that a district court generally loses jurisdiction over an action after a stipulated dismissal under Rule 41(a)(1)(ii). Under the Supreme Court’s decision in Kokkonen v. Guardian Life Insurance Co. of America, a court may retain authority to enforce a settlement if it incorporates the settlement into the dismissal order or if the parties consent to the court’s retaining jurisdiction.

Here, the parties’ dismissal stipulation did not attach or mention the settlement agreement. The parties also did not ask the court to retain jurisdiction to enforce the settlement. The court therefore concluded that its earlier dismissal order did not retain jurisdiction and that the court lacked jurisdiction to enter the requested judgment.

Disposition

Judge Liam Alsup denied the application. The order stated that any effort to enforce the settlement agreement must be brought as a new action in state court or, if federal jurisdiction can be shown, in federal court.