Woloszynska v. Netflix, Inc.

Background

Plaintiffs, including Maja Woloszyńska, a minor, filed this action against Netflix, Inc., and other defendants. The parties later settled the case. After the court directed plaintiffs to file for dismissal under Federal Rule of Civil Procedure 41, the court asked whether Maja’s claims were covered by the settlement or whether she was exempt from the court’s review of a minor’s settlement.

Plaintiffs responded that they believed the settlement met the requirements for resolving a minor’s claims because the agreement had been negotiated and approved by a magistrate judge. They did not, however, provide a showing that Maja’s settlement met those requirements or state that she was exempt. At the court’s request, plaintiffs submitted a sealed copy of the settlement.

Legal standard

The court explained that Federal Rule of Civil Procedure 17(c) gives district courts a special duty to protect minors who are parties. Under the standard described in Robidoux v. Rosengren, the court evaluates whether each minor’s net recovery is fair and reasonable, without comparing it to the amounts received by adult plaintiffs or the amounts agreed to be paid to plaintiffs’ counsel. The court also noted that courts in the Ninth Circuit apply this approach to state-law claims and commonly require money awarded to a minor to be deposited into a blocked account, meaning an account restricted for the minor’s benefit.

Ruling

The court found that plaintiffs had not shown that the settlement proceeds would be distributed in a way establishing that Maja’s net recovery was fair and reasonable. It ordered plaintiffs to file a motion to approve the minor’s settlement no later than February 21, 2024. The motion must propose how the settlement funds will be distributed and explain how Maja’s funds will be placed in a blocked account. The order did not itself approve the minor’s settlement.