Roberts v. Ford Motor Company
- Proceeding
- district
- Area
- civil
- Panel
- William Q. Hayes (author)
Analysis
Plaintiff Denise Roberts, a pro se litigant, moved to review and reconsider a settlement agreement in a vehicle warranty case, arguing she signed under duress and lacked legal representation. The Court denied the motion, holding that it has no obligation to review settlements between competent adults or provide legal advice to pro se litigants.
| What the court decided | The model |
|---|---|
Motion to Review and Reconsider Settlement Agreement Denied“For the reasons explained above, Plaintiffs request that the Court reassure her that the agreed-to settlement of her claims is fair, reasonable and legal exceeds those limits. Accordingly, Plaintiffs Motion is DENIED.” | agree with court The court correctly applied the principle that federal courts do not review the fairness of private settlements between competent adults absent specific statutory or rule-based requirements (such as for minors or incompetents). Furthermore, the court correctly cited binding authority establishing that judges cannot act as counsel or provide legal advice to pro se litigants. The plaintiff's request for the court to validate the settlement's legality and fairness is a request for legal advice, which is prohibited. |
The order itself: sound — The order is sound. It correctly identifies that the plaintiff is seeking legal advice regarding the validity of a private settlement, which is outside the court's role. The court cites appropriate Supreme Court and Ninth Circuit authority to support the proposition that judges must remain impartial and cannot act as counsel for pro se parties. The reasoning directly addresses the plaintiff's argument that her pro se status entitles her to special consideration, refuting it with binding precedent.
Opinion
1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 DENISE ROBERTS, an individual, Case No.: 24-cv-1424-WQH-DDL 12 Plaintiff, ORDER DENYING MOTION TO 13 v. REVIEW SETTLEMENT TERMS 14 FORD MOTOR COMPANY, and DOES 1 through 10, inclusive, 15 [Dkt. No. 21] Defendants. 16 17 Before the Court is Plaintiff Denise Roberts’s “Motion to Review and Reconsider 18 Settlement Agreement Due to Lack of Legal Representation and Signing Under Duress.” 19 Dkt. No. 21. The Motion has been referred to the undersigned for decision. Dkt. No. 22. 20 In her Motion, Plaintiff explains that she is “unsure if the settlement was fair and reasonable 21 and is seeking the Court’s assistance in reviewing its terms to ensure they comply with the 22 law.” Dkt. No. 21 at 2. For the reasons stated below, the Motion is DENIED. 23 As a general rule, the Court does not review settlements of non-class claims where 24 all settling parties are competent adults. Cf. CivLR 17.1 (requiring Court’s review and 25 approval of settlements on behalf of minors and incompetents). Moreover, it is not the 26 Court’s function to provide the parties in this vehicle warranty case with “guidance in 27 assuring the[ir] settlement is just and complies with all applicable legal standards.” Dkt. 28 No. 21 at 4. Notwithstanding what Plaintiff describes as her “unique position as a pro se | || litigant,” Dkt. No. 21 at 4, neither Plaintiff nor any other party to this action is entitled to 2 || legal advice from the Court. See, e.g., Pliler v. Ford, 542 U.S. 225, 231 (2004) (“District 3 judges have no obligation to act as counsel or paralegal to pro se litigants.”); Jacobsen v. 4 || Filler, 790 F.2d 1362, 1366 (9th Cir. 1986) (rejecting pro se party’s argument that it was 5 || the court’s “duty” to advise him because “pro se litigants in the ordinary civil case should 6 be treated more favorably than parties with attorneys”); Gragg v. Atascadero Police 7 || Dep’t, No. CV2106736MEMFKS, 2023 WL 4352074, at *1 (C.D. Cal. July 5, 2023) (“The 8 ||Court cannot provide legal advice to any party, including pro se litigants ...”). As the 9 ||Supreme Court has explained, requiring courts to dispense legal advice to parties is 10 || antithetical to the judge’s “role as [an] impartial decisionmaker[].” Pliler, 542 U.S. at 231; 11 || accord Jacobsen, 790 F.2d at 1366 (noting that “to give [a party legal] advice would entail 12 || the district court’s becoming a player in the adversary process rather than remaining its 13 ||referee”’). The Court finds no basis in the record before it to depart from these well- 14 || established principles. 15 “There are limits to what a court must do to accommodate a party appearing pro 16 ||se.” Washington v. Kijakazi, 72 F.4th 1029, 1040 (9th Cir. 2023). For the reasons 17 || explained above, Plaintiffs request that the Court reassure her that the agreed-to settlement 18 |/of her claims is fair, reasonable and legal exceeds those limits. Accordingly, Plaintiffs 19 || Motion is DENIED. The Settlement Disposition Conference remains as set for January 20 2025 at 1:00 p.m. (see Dkt. No. 19) but will be vacated upon the filing of the 21 appropriate motion or stipulation pursuant to Federal Rule of Civil Procedure 41. 22 || IT ISSO ORDERED. 23 || Dated: November 20, 2024 _—_— 24 Tb Lh, 25 “Hon.DavidD.Leshner SCS 26 United States Magistrate Judge 27 28