Williams v. Goetzes Candy Company, Inc.

Background

Milton Williams and Goetzes Candy Company, Inc. asked the court to approve a proposed consent decree. The parties negotiated the decree to settle the litigation. The defendant stated that it did not admit liability, but that it had reached an early individual settlement to avoid litigation costs and address the issues raised by the case.

The defendant also acknowledged that the proposed decree was intended to protect it from similar claims by other plaintiffs concerning the website-accessibility issues addressed by the settlement. Williams had initially brought the case as a purported class action, but the case had not been certified as a class action.

Court’s Analysis

The court explained that a federal court is not merely a recorder of private contracts. Before giving a settlement judicial approval, a court must examine the proposed agreement and ensure that its approval would not place the court’s authority behind an unlawful or otherwise improper decree.

The court concluded that the parties had not provided enough information to determine that the proposed decree’s terms were appropriate. The record did not allow the court to conclude that the decree would resolve all current and potential future website issues. The court also focused on the decree’s possible effect on absent potential class members and other website users. Although the case was not certified as a class action, the proposed decree would allow Williams and his counsel, together with the defendant, to determine what the defendant had to do to make its website comply with the Americans with Disabilities Act and similar statutes. The proposed resolution could therefore bind people who had not received notice or an opportunity to participate.

The court further stated that protecting a party and the court from duplicative litigation was not, by itself, enough to justify judicial approval of the private agreement. The fact that other courts had approved similar requests did not change the court’s conclusion.

Disposition

The court declined to enter the proposed consent decree. It stated that it would enter a separate “30-day order” in light of the parties’ settlement. If the parties wished to litigate the case’s merits after the court’s refusal to approve the decree, they could use the process described in that order to restore the case to the active docket. The opinion does not state that the case was dismissed or that the court decided whether the website violated the Americans with Disabilities Act.