Doss v. County of Alameda

Background

Guardians ad litem Lilly Coleman and Chastity Williams asked the court to approve compromises of the claims belonging to minors B.A. and O.A., respectively. The claims were brought against the County of Alameda and other defendants and arose from the death of the minors’ father, Dujuan Armstrong, while he was detained at Santa Rita Jail on June 23, 2018. The opinion states that the plaintiffs alleged jail officers and medical personnel acted with deliberate indifference to Armstrong’s need for medical help for almost 24 hours. They also alleged that officers used force and restraints, including a WRAP device and a spit mask, and that the coroner’s report attributed Armstrong’s death to asphyxiation during the restraint. The plaintiffs further alleged that county officials placed a media hold on the coroner’s report.

The minors asserted claims under 42 U.S.C. § 1983, California Civil Code § 52.1, California Government Code § 845.6, and common law. The petitions were unopposed.

Settlement Terms

The gross settlement was $2,700,000. B.A. and O.A. were each to receive a net settlement of $748,382.95. The opinion states that each minor’s gross allocation was $900,000, reduced by $150,000 in attorneys’ fees and $1,617.05 in litigation costs. Each minor’s settlement was structured as a tax-free annuity.

For O.A., the settlement provided monthly payments of $1,825 to guardian ad litem Chastity Williams from November 1, 2022, through February 1, 2037. O.A. was then to receive $5,000 monthly for 12 years, through February 1, 2049, plus guaranteed lump sums of $75,000 on February 11, 2041; $100,000 on February 11, 2044; and $378,085.27 on February 11, 2049.

For B.A., the settlement provided monthly payments of $3,000 to guardian ad litem Lilly Coleman from November 1, 2022, through May 1, 2030. B.A. was then to receive $5,000 monthly for 12 years, through May 1, 2042, plus guaranteed lump sums of $20,000 on May 12, 2034; $40,000 on May 12, 2037; and $144,770.70 on May 12, 2042. The order stated that the guardians could receive only the specified monthly payments and had to use those funds exclusively for the benefit of the respective minor.

Legal Standard

Federal Rule of Civil Procedure 17(c) requires district courts to protect the interests of minor litigants. The court therefore had to independently determine whether each proposed settlement was fair, reasonable, and in that minor’s best interests, even though the settlement had been negotiated or recommended by a guardian ad litem. The court applied the approach described in Robidoux v. Rosengren to all of the minors’ claims, including their state-law claims.

Under that approach, the court focused on whether each minor’s net recovery was fair and reasonable in light of the minor’s claims and recoveries in similar cases. The court expressly stated that it was not deciding whether the amounts allocated to the adult plaintiff or the attorneys’ fees were fair or reasonable.

Ruling

The court found the settlement fair and reasonable and in the best interests of both O.A. and B.A. It emphasized the parties’ agreement, the use of regular annuity payments and guaranteed lump sums, and the wide range of recoveries in similar cases. The court concluded that a net recovery of $748,382.95 for each minor was fair and reasonable under the circumstances.

The court GRANTED the petitions for approval of the minors’ compromises. It directed payment of $1,203,234.10 to the Law Office of John L. Burris Client Trust Account for immediate cash, funding for court-blocked accounts, attorneys’ fees, and litigation costs; $748,382.95 to New York Life Insurance Company for O.A.’s annuity; and $748,382.95 to Metlife Assignment Company for B.A.’s annuity. The parties were ordered to execute settlement agreements and releases, and to promptly file a stipulated dismissal.