Camarlinghi v. Santa Clara County

Background

Dylan Camarlinghi filed a putative class action against Santa Clara County, alleging that the County violated his and similarly situated people’s constitutional rights by failing to release them within a reasonable time after the district attorney declined to prosecute them. The complaint asserted two claims under 42 U.S.C. § 1983, a federal law allowing claims against state or local actors for constitutional violations, based on substantive and procedural due process.

The parties reached an early settlement before formal class certification after informal discovery, settlement negotiations, and multiple settlement conferences. The proposed settlement class covered:

- People detained at the jail from 12 up to 24 hours after the district attorney declined prosecution, when no hold, warrant, or other reason justified continued detention, during the period from April 26, 2018, through April 26, 2021; and - People detained at the jail for 24 hours or longer after the district attorney declined prosecution, under the same conditions and during the same period.

The court had conditionally certified the settlement class in its preliminary approval order and appointed class counsel and American Legal Claim Services, LLC as settlement administrator. The settlement class included 244 members.

Settlement Terms and Notice

Santa Clara County agreed to pay $2,375,000 into a non-reversionary settlement fund without admitting liability. The fund covers notice and administration costs, the class representative’s incentive award, attorneys’ fees and expenses, and valid claims by class members.

After deductions, approximately $1,980,000, or 84 percent of the fund, was expected to remain for participating class members. Subclass I members would receive $250 for each hour of compensable detention from 12 up to 24 hours. Subclass II members would receive $250 for each hour from 12 to 24 hours and $295 for each hour over 24 hours. In exchange for settlement payments, class members would release claims against the County as provided in the settlement agreement.

The settlement administrator mailed 240 notices, used address-location services, and maintained a website with information and forms in English, Spanish, and Vietnamese. Four class members were not sent notices. As of November 28, 2022, the administrator had received 73 completed claim forms. No objections or requests to opt out were received by the deadline.

Final Approval

Under Federal Rule of Civil Procedure 23, a court may approve a class settlement after a hearing if it finds the settlement fair, reasonable, and adequate and determines that the class-certification requirements are met. Because this settlement was reached before formal certification, the court applied a heightened review for possible conflicts between class counsel’s interests and the class’s interests.

The court found that the class met the requirements for certification. It concluded that the class was sufficiently numerous, had common issues concerning excessive detention after a decision not to prosecute, and that Camarlinghi’s claims were typical of the class. The court also found that Camarlinghi and class counsel adequately represented the class and that common issues predominated over individual ones, making a class action superior to other methods of resolving the claims.

The court found that the notice procedures were adequate. It also found the settlement fair and reasonable because trial would have been costly, recovery was not guaranteed, appeals could have prolonged the case, the negotiations were informed and conducted at arm’s length, and the payment structure treated class members equitably according to the length of their detention. The lack of objections or opt-outs also supported approval.

The court therefore granted the motion for final approval of the proposed class action settlement, granted certification of the settlement class, and confirmed the provisional appointments of the class representative and class counsel.

Attorneys’ Fees, Costs, and Incentive Award

The settlement allocated $395,000 for attorneys’ fees and expenses, settlement administration, and the incentive award. Up to $50,000 could be used for administration, and $20,000 was requested for Camarlinghi. The remaining amount was allocated to class counsel for attorneys’ fees, costs, and expenses.

The court found the requested attorneys’ fees reasonable under both the percentage-of-the-fund method and the lodestar method. The fees were expected to be between $325,000 and $375,000, depending on administration costs, representing approximately 13.6 to 15.8 percent of the settlement fund. The court compared that amount with the Ninth Circuit’s 25-percent benchmark and with a lodestar of $308,229.50 based on 504 hours of work by attorneys, legal directors, paralegals, and investigators.

The court awarded class counsel $2,530.52 in litigation costs. It also approved Camarlinghi’s $20,000 incentive award, finding that he had accepted reputational risk, assisted with the investigation, communicated with counsel, and participated in a settlement conference while representing the interests of the other class members.

Order

Judge Edward J. Davila granted the motion for final approval of the proposed class action settlement. The court granted the motion concerning the $395,000 allocation for fees, costs, and the incentive award as follows: class counsel received $2,530.52 in litigation costs; Camarlinghi received a $20,000 incentive award; and, after payment of up to $50,000 in settlement-administration costs, class counsel received the remainder as attorneys’ fees. The court retained jurisdiction over matters concerning interpretation, administration, implementation, effectuation, and enforcement of the order and settlement, including any future designation of a charitable recipient for residual funds. The parties were ordered to file a post-distribution accounting by October 2, 2023.