1 UNITED STATES DISTRICT COURT 2 NORTHERN DISTRICT OF CALIFORNIA 3 4 RODRIC P. STANLEY, JR., Case No. 24-cv-06493-JD

5 Plaintiff,

ORDER RE MOTION TO DISMISS

v. 6 Re: Dkt. Nos. 15, 21, 22 7 SGT HOLLAND, et al., Defendants. 8

9 10 Plaintiff, a former detainee and current prisoner, filed a pro se civil rights complaint under 11 42 U.S.C. § 1983. Defendants filed a motion to dismiss the complaint or in the alternative, to 12 enforce a prior global settlement agreement. Dkt. No. 15. Plaintiff filed an opposition (Dkt. No. 13 17), defendants filed a reply (Dkt. No. 18), and plaintiff filed a sur-reply (Dkt. No. 19).1 14 Defendants’ motion is granted. 15 BACKGROUND 16 On August 15, 2024, plaintiff, represented by counsel in a separate case before the Court, 17 entered into a global settlement of multiple civil rights actions against Contra Costa County and its 18 employees. Request for Judicial Notice (“RJN”), Ex. A.2 The agreement did not specifically 19 identify this case because the case was filed after the agreement was signed.3 However, as part of 20 the settlement, plaintiff agreed to release and discharge the county and its employees from any 21 claims, right or cause of action arising out of any incidents at the jails from September 2018 to the 22 date the agreement was fully executed, August 15, 2024. RJN, Ex. A at 2-3. The parties agreed 23 1 Defendants filed an objection to plaintiff’s sur-reply, arguing that it violated local rules. Dkt. 24 No. 20. Considering plaintiff’s status as an incarcerated litigant proceeding pro se, the Court will review the sur-reply. 25 2 The Court grants defendants’ request that the Court take judicial notice of the settlement from Stanley v. McClay, et al., Case No. 21-cv-4496 JD, that was filed in Stanley v. Maldonado, Case 26 No. 23-cv-0292 JD, Dkt. No. 29, Ex. A. Court filings and records are appropriate for judicial notice. See Fed. R. Ev. 201(b)(2); Pasta Bella, LLC v. Visa USA, Inc., 442 F.3d 741, 746 n.6 (9th 27 Cir. 2006). 1 that such claims would be released and settled. Id. at 3. The settlement agreement was finalized 2 and signed, the settlement money was paid, and the parties filed a stipulation for dismissal of the 3 relevant actions. Dkt. No. 15 at 4. 4 In this complaint, plaintiff alleges that in August 2022, deputies at Contra Costa County 5 Jail violated his rights regarding living conditions and by placing him into solitary confinement 6 without any due process. Dkt. No. 11 at 3. This case was filed on September 5, 2024, 7 approximately three weeks after the signing of the settlement agreement. Dkt. No. 1-1 at 1. 8 LEGAL STANDARDS 9 Settlement Agreement 10 Settlement agreements are contracts. See Rouser v. White, 825 F.3d 1076, 1081 (9th Cir. 11 2016). The settlement agreement is “treated as any other contract for purposes of interpretation.” 12 United Com. Ins. Serv., Inc. v. Paymaster Corp., 962 F.2d 853, 856 (9th Cir. 1992). Thus, the 13 interpretation and enforcement of settlement agreements are governed by principles of state law, 14 which apply to contracts generally. Jeff D. v. Andrus, 899 F.2d 753, 759 (9th Cir. 1990); Wilcox v. 15 Arpaio, 753 F.3d 872, 876 (9th Cir. 2014) (“[S]tate contract law governs whether [the parties] 16 reached an enforceable agreement settling the federal and state law claims alleged in Plaintiffs’ 17 complaint.”). 18 Under California law, contract formation requires (1) parties capable of contracting; (2) the 19 parties’ consent; (3) a lawful object; and (4) sufficient cause or consideration. Lopez v. Charles 20 Schwab & Co., 118 Cal. App. 4th 1224, 1230 (Cal. Ct. App. 2004) (citing Cal. Civ. Code § 1550). 21 The clear and explicit meaning of the contract provisions, interpreted in their ordinary and popular 22 sense, controls judicial interpretation. Cal. Civ. Code, §§ 1638, 1644; U.S. Bank N.A. v. 23 Yashouafar, 232 Cal. App. 4th 639, 646 (2014). 24 Release of Claims 25 The “conditions affecting the validity of a release of significant federal rights are 26 eminently a matter of federal law.” Jones v. Taber, 648 F.2d 1201, 1203 (9th Cir. 1981). Federal 27 common law, rather than state law, controls the effect and interpretation of a release of a Section 1 A release of claims for violations of civil and constitutional rights must be voluntary, 2 deliberate, and informed. Jones, 648 F.2d at 1203. “There are both subjective and objective 3 aspects to each of these elements.” Id. Whether a release is voluntary, deliberate, and informed is 4 determined on a case-by-case basis considering the totality of the circumstances surrounding the 5 execution of the release. See Stroman v. W. Coast Grocery Co., 884 F.2d 458, 462 (9th Cir. 6 1989). Further, under federal law, a valid release must be supported by consideration. Salmeron 7 v. United States, 724 F.2d 1357, 1362 (9th Cir. 1983). 8 DISCUSSION 9 The events in the complaint occurred in 2022, at a Contra Costa County Jail. In the 10 settlement agreement, plaintiff agreed to waive and release Contra Costa County and its 11 employees from all claims relating to his detention in the county jails between September 2018 12 and August 15, 2024. Defendants say that the claims in this complaint were released through the 13 settlement agreement and this case should be dismissed or in the alternative the Court should 14 enforce the settlement to dismiss the case. 15 The point is well taken. Plaintiff says that this case was not referenced in the settlement 16 agreement, and so is not within the agreement and should continue. Dkt. No. 17 a 1, 3-4.4 That is 17 not the right inquiry. What matters is that the events in the complaint occurred within the period 18 for which plaintiff released all claims. It bears mention that plaintiff was represented by counsel 19 during the settlement proceedings. 20 Plaintiff says that he was in solitary confinement in April 2024, had recently been found 21 guilty at his criminal trial, and was suffering psychologically and emotionally as a result. Dkt. 22 No.17 at 2. He states that in June 2024 he was attacked by deputies, which caused him a great 23 deal of pain, suffering, and emotional distress. Id. at 3. He also states that he was withdrawing 24 from narcotic pain medication in June 2024, resulting in the filing of one grievance on June 8, 25 2024. Id. As a result of these events, plaintiff says he was irritated, incompetent, and not thinking 26 logically when signing documents in August 2024. Id. 27 1 In California, everyone is capable of contracting “except minors, persons of unsound mind, 2 and persons deprived of civil rights.” Cal. Civ. Code § 1556. California law provides that “[a] 3 conveyance or other contract of a person of unsound mind, but not entirely without understanding, 4 made before the incapacity of the person has been judicially determined, is subject to rescission. . . 5 .” Id. § 39(a). California law also creates a rebuttable presumption that a person’s mind is 6 unsound “if the person is substantially unable to manage his or her own financial resources or 7 resist fraud or undue influence. Substantial inability may not be proved solely by isolated 8 incidents of negligence or improvidence.” Id. § 39(b). 9 “[A] party is entitled to rescission of a contract if, when he entered into the contract, he 10 was not mentally competent to deal with the subject before him with a full understanding of his 11 rights . . .” In re Rains, 428 F.3d 893, 901 (9th Cir. 2005) (quoting Smalley v. Baker, 262 12 Cal.App.2d 824, 832 (1968), overruled on other grounds by Weiner v. Fleischman, 54 Cal.3d 476, 13 286 (1991). The test is whether they understand the nature, purpose, and effect of what they are 14 doing. Id. 15 Other than his conclusory allegations that he was not competent to enter into the 16 agreement, plaintiff offers little evidentiary support. Defendants noted this in their reply and 17 plaintiff submitted an additional filing demonstrating that he was treated for chronic lower back 18 pain in 2020 and 2021. Dkt. No. 19 at 10-11. Plaintiff does not describe how medical care several 19 years earlier is relevant, and even assuming plaintiff was experiencing all the issues he describes, 20 he has not adequately shown that he was incompetent pursuant to the legal standards above. Nor 21 does he address that he was represented by counsel during this time and if he communicated these 22 issues with counsel or the process in which counsel communicated with him regarding the terms 23 of the agreement. Despite two separate filings, plaintiff has failed to present sufficient arguments 24 or evidence. At most he has shown isolated incidents of confusion or improvidence several 25 weeks, months, and years before the agreement was signed. For example, while he was having 26 issues with pain medication on June 8, 2024, he has not described how that affected him when the 27 agreement was signed on August 15, 2024. 1 The Court also notes that between July and September 2024, when plaintiff states that he 2 was not competent, he was able to file the instant complaint and a separate civil rights complaint 3 in Stanley v. Shiffer, et al., Case No. 24-cv-4282 JD. The complaints in both actions were 4 thorough and well-reasoned, and in both cases the Court ordered service of the claims without 5 requiring amendment. Plaintiff’s general and conclusory allegations that he was incompetent 6 during this time are insufficient. He has failed to show a lack of understanding the nature, 7 purpose, and effect of the agreement. 8 Defendants have demonstrated that the parties entered into an agreement and that these 9 claims were released. Defendants presented the Court with sufficient evidence showing that the 10 parties entered into a valid contract under California law. Defendants demonstrated that the 11 parties were capable of contracting, there was consent, a settlement agreement is a lawful object, 12 and plaintiff was provided consideration. 13 The totality of the circumstances surrounding the execution of the release also show that 14 plaintiff agreed to a release of claims from the county jails during the relevant time. As noted 15 above, plaintiff’s bare allegations that he was incompetent are not supported, and the totality of the 16 circumstances reflect that the release was voluntary, deliberate, and informed. The agreement and 17 release resolved all claims against the county and its employees during the time at issue. Plaintiff 18 accepted the global settlement amount of thirty thousand dollars. 19 Plaintiff, while represented by counsel, signed the settlement paperwork and accepted the 20 funds. He contends that he would have negotiated for more money if he knew the claims from the 21 instant complaint were part of the agreement. Dkt. No. 17 at 6. Plaintiff’s assertion is 22 contradicted by the clear language of the agreement. He cannot now alter the terms of the 23 agreement to re-negotiate the value of his claims in this case. See, e.g., Doi v. Halekulani Corp., 24 276 F.3d 1131, 1141 (9th Cir. 2002) (“[W]e cannot countenance a plaintiff’s agreeing to settle a 25 case in open court, then subsequently disavowing the settlement when it suits her.”); Spitzer v. 26 Aljoe, 734 F. App’x 457, 459 (9th Cir. 2018) (affirming district court’s denial of plaintiff’s motion 27 to rescind settlement reached between the parties after mediation). Defendants have shown that 1 || the settlement.° 2 CONCLUSION 3 1. Defendants’ motion to dismiss (Dkt. No. 15) is granted. Plaintiff's motion for 4 sanctions because he did not receive any Court mail (Dkt. No. 21) is denied. The Court did not 5 send plaintiff any mail, thus there was no interference with his legal mail. Plaintiffs motion for 6 || the Court to review the motions to dismiss (Dkt. No. 22) is granted. 7 2. The Clerk is requested to terminate all pending motions, enter judgment, and close 8 || the file. 9 IT IS SO ORDERED. 10 Dated: December 11, 2025 11 12

JAMES ‘ATO

13 United Stes District Judge © 15 16

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Z 18

19 20 21 22 23 24 25 26 27 28 > Because the Court has granted the motion to dismiss, the motion to enforce the settlement agreement will not be addressed.