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Board of Trustees of the Glaziers, Architectural Metal & Glass Workers Local Union 1399 Health & Welfare Trust v. Summit Commercial Floors, Inc.

District Court, S.D. California · 3:21-cv-00081 · 2021-06-23 · Unknown

Proceeding
district
Area
civil
Panel
Roger T. Benitez (author)

Analysis

A model's reading — qwen3.8-27b, prompt own-v1, 2026-10-13T23:00Z · confidence high

The court considered a second motion by the plaintiff for entry of a stipulated judgment following a settlement in an ERISA action. The court denied the motion, holding that the settlement eliminated the Article III case or controversy, and directed the parties to file a stipulation of dismissal under Rule 41(a)(1) within 30 days.

What the court decidedThe model
Motion for Entry of Stipulated Judgment (ECF No. 17) denied
“Thus, no reason for the Court’s analysis or reasoning outlined in its previous order warrants a different outcome here.”
agree with court
The court correctly applied the principle that federal courts lack subject matter jurisdiction once a case is settled and no live controversy remains. The order notes that the new motion failed to address the jurisdictional defect identified in the prior order and that the parties have a legally enforceable settlement. The directive to dismiss under Rule 41(a)(1) is the standard procedural mechanism for voluntary dismissal by stipulation.
Parties directed to file Stipulation or Notice of Dismissal pursuant to Rule 41(a)(1) within 30 days
“Plaintiff and Defendant are directed to file a Stipulation or Notice of Dismissal pursuant to Rule 41(a)(1) of the Federal Rules of Civil Procedure within thirty (30) days of this order.”
agree with court
This is a standard procedural directive to close the case via voluntary dismissal, which is appropriate given the lack of jurisdiction to enter judgment on the merits or a stipulated judgment.

The order itself: sound — The order is procedurally sound. It correctly identifies that the settlement moots the case, citing the prior order and supporting authority (Wigton). It properly denies the motion for stipulated judgment and directs the parties to use the correct procedural mechanism (Rule 41(a)(1) dismissal) to close the case. The reasoning is consistent with federal jurisdictional principles.

How this analysis was made · dispute it

record incomplete

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 BOARD OF TRUSTEES OF THE ) Case No.: 3:21-cv-00081-BEN-AHG GLAZIERS, ARCHITECTURAL, ) 12 METAL & GLASS WORKERS LOCAL ) ORDER DENYING MOTION FOR 13 UNION #1399 HEALTH & WELFARE ) ENTRY OF STIPULATED TRUST, ) JUDGMENT 14 ) Plaintiff, 15 ) [ECF No. 17] v. ) 16 ) SUMMIT COMMERCIAL FLOORS, 17 ) INC., a California corporation, ) 18 Defendant. ) 19 20 Plaintiff BOARD OF TRUSTEES OF THE GLAZIERS, ARCHITECTURAL 21 METAL & GLASS WORKERS LOCAL UNION #1399 HEALTH & WELFARE TRUST 22 (“Plaintiff”) brings this action to redress violations or enforce the terms of Section 502(e) 23 of the Employee Retirement Income Security Act of 1974 (“ERISA”), as amended, 29 24 U.S.C § 1132(e), against Defendant SUMMIT COMMERCIAL FLOORS, INC., a 25 California corporation (“Defendant” or “Summit”). Complaint, ECF No. 1 (“Compl.”). 26 A detailed factual and procedural background was set forth in the Court’s previous 27 order and is incorporated herein. See Bd. of Trustees of Glaziers, Architectural, Metal & 28 Glass Workers Loc. Union #1399 Health & Welfare Tr. v. Summit Com. Floors, Inc., No. 1 321CV00081BENAHG, 2021 WL 2014793, at *1 (S.D. Cal. May 20, 2021). In that May 2 19, 2021 Order, this Court issued denied the first Motion for Entry of Stipulated Judgment 3 filed in this case, see ECF No. 13, “as moot given (1) the settlement terms have already 4 been read into the record and (2) resolution of all claims between the parties brings the 5 Court’s Article III jurisdiction into question.” See ECF No. 18. 6 The Court’s previous order elaborated that once the parties have settled a case, no 7 live case or controversy exists, meaning the Court lacks jurisdiction to take any action in 8 the matter pursuant to Article III of the United States Constitution. Compare ECF No. 18 9 at 4-8 (citing Wigton v. Murphy, 410 F. Supp. 3d 1121, 1121-22 (D. Mont. 2019) (denying 10 a Motion to Approve a Stipulation for Entry of Judgement because the settlement of the 11 claims in a case where no ongoing monitoring is required (such as consent decrees) means 12 there is no longer an Article III “case or controversy” sufficient to vest the court, a court of 13 limited jurisdiction, with subject matter jurisdiction) with U.S. CONST., ART. III, § 2 14 (limiting the subject-matter jurisdiction of federal courts to justiciable “cases” and 15 “controversies”). The Court reiterated that as other courts have pointed out, the proper 16 course of action once a settlement has been finalized is to file a stipulation for dismissal 17 pursuant to Rule 41(a)(1) of the Federal Rules of Civil Procedure. See id. at 8; see also 18 Wigton, 410 F. Supp. 3d at 1122 (noting that a stipulated judgment “grants an advisory 19 opinion about reasonable settlement amounts and turns the court’s imprimatur into a 20 tactical and strategic tool”). 21 The same day of the Court’s previous order, May 19, 2021, counsel for Plaintiff filed 22 yet another Motion for Entry of Stipulated Judgment, which again asked the Court to enter 23 judgment despite the settlement between the parties and despite the Court’s order denying 24 a motion brought on the same grounds. See ECF No. 17. Although Plaintiff requested less 25 relief than previously (by removing certain requests for relief that were never even included 26 in the original complaint), this new motion failed to address any of the issues set forth in 27 the Court’s previous order. For instance, it provided no reasoning or legal authority 28 addressing the Court’s lack of jurisdiction in light of the absence of a case or controversy ! |) when the parties have settled a case. The Court’s independent review of legal authority 2 also finds no reason to reverse the outcome of its previous order. Thus, no reason for the 3 Court’s analysis or reasoning outlined in its previous order warrants a different outcome 4 || here. 5 Plaintiff and Defendant have a written settlement that has been filed with the Court © || and have also entered the settlement terms on the record before Magistrate Judge Allison 7 Goddard. Thus, they have a legally enforceable settlement. Should Plaintiff need to do 8 so, Plaintiff can bring an action to enforce those settlement terms at any time. However, 9 seeing as the parties have reached a settlement, no case or controversy exists for the Court 10 adjudicate. Plaintiff and Defendant are directed to file a Stipulation or Notice of 11 | Dismissal pursuant to Rule 41(a)(1) of the Federal Rules of Civil Procedure within thirty 12 (30) days of this order. If no such filing is made by Wednesday, July 21, 2021, the Court 13 || will set an Order to Show Cause as to why this case should not be dismissed. 14 IT IS SO ORDERED. " 15 || DATED: June 22, 2021 16 HON. ROGER T. BENITE 7 United States District Judge 18 19 20 21 22 23 24 25 26 27 28 3.