Horton v. Molina
- Jacquelyn Corley
- 3:17-cv-01915-JSC
- U.S. District Court · Northern District of California
- 4
In Horton v. Molina, Judge Corley enforced the parties’ settlement, requiring payment and dismissal, but declined to add a release for nonparties or a payment deadline.
Michael J. Horton and Defendant Molina are affected by the enforced settlement. The order requires the specified payment, dismissal of Horton’s action with prejudice, and each party’s responsibility for its own fees and costs; it does not add a release for nonparties or a payment-timing term.
What happened
In Michael J. Horton v. Parsons, et al., the parties settled an excessive-force case shortly before trial. Their emails stated that Defendant Molina, or the California Department of Corrections and Rehabilitation on his behalf, would pay $45,000, with specified deductions, and that Horton would dismiss the case with prejudice while each side paid its own fees and costs.
The parties later disagreed about the written settlement. Molina wanted Horton to release the Department and other people who were not parties to the case, and the parties also disagreed about when payment had to be made. Molina asked the court to enforce the settlement.
Judge Jacqueline Scott Corley granted the motion and enforced the terms stated in the emails. She required the specified payment and dismissal, but did not add a release for nonparties or a payment-timing term because those terms were not part of the agreement described in the emails.
The detailed version
- Horton v. Molina · No. 3:17-cv-01915-JSC
- Jacquelyn Corley
- Feb. 13, 2023
Background
A jury trial in Horton’s excessive-force case was scheduled for October 24, 2022. The parties informed the court shortly before trial that they had settled the action. More than three months later, the case had not been dismissed, and Defendant Molina moved to enforce the settlement.
During settlement discussions, Molina explained that amounts Horton still owed for restitution and fines would be deducted from the settlement payment. On October 21, 2022, Horton’s counsel sent defense counsel an email describing the proposed terms: Molina, or the California Department of Corrections and Rehabilitation on his behalf, would pay $45,000; $34,074.02 would be deducted for restitution, a five-percent administrative fee, and court costs, leaving Horton with a net payment of $10,925.98; Horton would dismiss the action with prejudice; and each party would pay its own fees and costs. Defense counsel replied, “We will agree to the terms and conditions below.” The parties then told the court they had reached a “full settlement.”
Dispute over the written agreement
The parties could not agree on a formal written settlement. Molina sought to have Horton sign the Department’s form agreement, including a release of the Department and other nonparties from claims arising from the facts alleged in the complaint. The parties also disagreed about the time for making the settlement payment.
The court explained that a settlement is a contract and that a federal district court may enforce a settlement of a case pending before it. Applying California law, the court held that the parties had agreed to all material settlement terms on October 21, 2022: the $45,000 payment, dismissal of the action with prejudice, and each party’s responsibility for its own fees and costs.
Court’s analysis
The court rejected Molina’s argument that the settlement was incomplete because the parties had not agreed on release language. Horton’s agreement to dismiss the action with prejudice operated as a final judgment on the merits and barred Horton’s claims. The court stated that the release Molina received through that dismissal was equivalent to the release resulting from a judgment in Molina’s favor. The court found no basis to require Horton to release claims against nonparties when the record did not show that such a condition had been communicated or agreed upon.
The court also declined to add a payment-timing term. The October 21 email exchange did not show that the parties had discussed or agreed on when payment would be made.
Disposition
The court granted Molina’s motion to enforce the settlement. It enforced these terms: Molina, or the Department on his behalf, must pay $45,000, reduced by $34,074.02 for the stated deductions, resulting in a net payment of $10,925.98 to Horton; Horton must dismiss the action with prejudice; and each party must bear its own fees and costs. The order disposes of Docket No. 176.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.