Sanchez v. Blockfi Inc.
- Valerie Caproni
- 1:21-cv-03803
- U.S. District Court · Southern District of New York
- 2
In Sanchez v. BlockFi Inc., Judge Caproni dismissed the settled case with prejudice, but the settlement did not bind absent putative class members.
Christian Sanchez and BlockFi Inc. were bound by the dismissal and any settlement between them. Absent putative class members were not bound. The parties also had 30 days to seek reopening or ask the court to retain jurisdiction to enforce the settlement.
What happened
In Sanchez v. BlockFi Inc., the parties told Judge Valerie Caproni that they had reached an agreement in principle resolving all issues. The opinion does not describe the agreement’s terms.
The court canceled scheduled conferences and deadlines, dismissed the case with prejudice and without costs or attorneys’ fees to either party, terminated open motions, and closed the case. The parties could ask to reopen the case within 30 days by showing good cause. The dismissal and any settlement applied only between Christian Sanchez and BlockFi Inc.; they did not bind absent putative class members because the parties had not said they would follow the required class-settlement procedures.
Judge Caproni also ordered the clerk to remove the class-action language from the caption and explained that the court could retain authority to enforce the settlement only if the parties timely submitted the agreement and requested that authority.
The detailed version
- Sanchez v. Blockfi Inc. · No. 1:21-cv-03803
- Valerie Caproni
- June 14, 2021
Background
Christian Sanchez brought the case on behalf of himself and all others similarly situated against BlockFi Inc. On June 11, 2021, the parties notified the court that they had reached an agreement in principle resolving all issues. The opinion does not provide the agreement’s terms.
Court’s Order
The court ordered that all previously scheduled conferences and other deadlines were canceled. It dismissed the case with prejudice and without costs, including attorneys’ fees, to either party. The clerk was directed to terminate all open motions and close the case.
The parties could apply to reopen the case within 30 days of the order. Such an application had to show good cause for keeping the case open despite the settlement and had to be filed within that 30-day period. The court stated that a late request or one without a showing of good cause could be denied solely for that reason.
If the parties wanted the court to retain jurisdiction—that is, authority to enforce the settlement agreement—they had to submit the agreement and request an order expressly retaining that authority within the same 30-day period.
Class Allegations
The court ordered the clerk to remove the phrase “individually and on behalf of all others similarly situated” from the caption. Because the parties had not notified the court that they intended to comply with Federal Rule of Civil Procedure 23(e), which governs certain class-action settlements and dismissals, the dismissal and any settlement operated only between Sanchez and BlockFi Inc. They did not bind absent putative class members.
Disposition
The case was dismissed with prejudice, without costs or attorneys’ fees to either party, and closed. The order did not decide the underlying claims on their merits. Judge Valerie Caproni entered the order on June 14, 2021.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.