K.C. v. Torlakson, No. 12-16178 (9th Cir. 2014)
Annotate this CasePlaintiffs filed a putative class action alleging that defendants failed to provide necessary services for students with diabetes in California public schools. The parties subsequently entered into a settlement agreement and the district court retained limited jurisdiction to enforce the agreement. After the district court's jurisdiction had expired per the terms of the settlement agreement, plaintiffs filed a motion seeking attorneys' fees for monitoring defendants' compliance with the agreement. The district court denied the motion for lack of jurisdiction. The court concluded that the district court erred in failing to recognize the distinction between ancillary jurisdiction to enforce the settlement agreement and ancillary jurisdiction over an attorney's fees dispute. While the settlement agreement limited the district court's ancillary jurisdiction to enforce the terms of the parties' settlement, it did not affect the district court's ancillary jurisdiction over an attorneys' fees dispute. Thus, the district court has ancillary jurisdiction over plaintiffs' motion for attorneys' fees. The court reversed and remanded.
Court Description: Ancillary Jurisdiction / Attorneys’ Fees. The panel reversed the district court’s denial, for lack of jurisdiction, of plaintiffs’ motion for attorneys’ fees for monitoring defendants’ compliance with a settlement agreement in an action under the Americans with Disabilities Act and other statutes concerning services for students with diabetes in California public schools. The district court retained limited jurisdiction to enforce the settlement agreement. Plaintiffs sought attorneys’ fees after the court’s jurisdiction to enforce the settlement agreement had expired under the terms of that agreement. The panel held that the motion for attorneys’ fees did not seek to enforce the settlement agreement; consequently, the conclusion that the district court lacked ancillary jurisdiction to enforce the settlement agreement was irrelevant. The panel also held that the district court independently had ancillary jurisdiction over the post-judgment attorneys’ fees dispute, irrespective of the fact that the court’s jurisdiction to enforce the settlement agreement had expired. The panel remanded for the district court in its discretion to decide whether to exercise ancillary jurisdiction over the motion for attorneys’ fees.
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