Alvin James Smith v. Equifax Inc. and Does 1–100
- Proceeding
- district
- Area
- civil
- Panel
- Cathy Ann Bencivengo (author)
Analysis
The court considered Plaintiff's motion for reconsideration seeking to enforce a settlement agreement following a dismissal with prejudice, and his motion to file documents under seal. The court denied the motion for reconsideration for lack of jurisdiction and denied the motion to file under seal as moot.
| What the court decided | The model |
|---|---|
Motion for Reconsideration Denied“Accordingly, the Court DENIES the motion for reconsideration” | agree with court The court correctly applied the rule from Kokkonen v. Guardian Life Ins. Co. of Am. that a federal court does not retain jurisdiction over a settlement agreement unless the dismissal order incorporates the agreement or explicitly retains jurisdiction. The order recites that the prior dismissal order did not do either, and the stipulation did not reference the settlement. Therefore, the court lacked subject matter jurisdiction to enforce the settlement. |
Motion to File Under Seal Denied as Moot“and DENIES as moot the motion to file documents under seal.” | agree with court Because the motion for reconsideration was denied, there are no further proceedings or documents to be filed in the case, rendering the motion to file under seal moot. |
The order itself: sound — The order correctly identifies the legal standard for retaining jurisdiction over settlement agreements and applies it to the specific facts of the prior dismissal order and stipulation. The reasoning is concise and directly addresses the jurisdictional defect.
Opinion
1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 ALVIN JAMES SMITH, Case No.: 3:24-cv-1737-CAB-DTF 12 Plaintiff, ORDER DENYING MOTIONS FOR 13 v. RECONSIDERATION AND TO FILE UNDER SEAL 14 EQUIFAX INC., and DOES 1–100, 15 Defendants. [Doc. Nos. 17–18] 16 17 On December 15, 2025, Plaintiff filed a motion for reconsideration pursuant to Fed. 18 R. Civ. P. 60(b) and a motion to file documents under seal. [Doc. Nos. 17–18.] He seeks 19 relief from the Court’s order on March 12, 2025, which granted the parties’ joint motion to 20 dismiss the case with prejudice. [Doc. No. 12.] Plaintiff asserts that Defendant Equifax 21 Inc. has breached the parties’ settlement agreement. [Doc. No. 17 at 2.] 22 “[A] federal court may retain jurisdiction over a settlement agreement where the 23 court’s order of dismissal incorporates the terms of the settlement agreement, or the order 24 of dismissal explicitly states that the court retains jurisdiction over the settlement.” 25 Gonzalez v. United States, No. 16CV1792-MMA (KSC), 2017 WL 1094074, at *6 (S.D. 26 Cal. Mar. 23, 2017) (citing Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 381 27 (1994)). The Court’s order of dismissal did not incorporate the terms of the settlement 28 agreement nor state that the Court would retain jurisdiction. Moreover, the parties’ joint 1 || stipulation of dismissal made no reference to any settlement agreement. [See Doc. No. 11.] 2 “‘[F]ederal courts do not have inherent or ancillary jurisdiction to enforce a settlement 3 ||agreement simply because the subject of that settlement was a federal lawsuit.” O’Connor 4 ||v. Colvin, 70 F.3d 530, 532 (9th Cir. 1995). Accordingly, the Court DENIES the motion 5 || for reconsideration and DENIES as moot the motion to file documents under seal. 6 It is SO ORDERED. 7 Dated: January 9, 2026 □ Z 8 Hon. Cathy Ann Bencivengo ? United States District Judge 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28