Disability Law Center v. Massachusetts Department of Correction
960 F. Supp. 2d 271
D. Mass.2012Background
- DLC sues the Massachusetts Department of Correction on behalf of mentally ill inmates for segregation-related harms and constitutional violations.
- Parties begin settlement discussions in 2007; court mediates per its stated preference for settlements in rights-issues cases.
- In December 2011 the parties reach a comprehensive Settlement Agreement subject to court approval and retention of jurisdiction.
- The Agreement seeks to reduce segregation, add Secure Treatment Units, enhance mental-health screening, and require periodic compliance reporting.
- Judge evaluates whether to approve the private settlement, stay litigation, and retain jurisdiction consistent with the PLRA and Kokkonen.
- If approved, the case would be stayed for up to three years (potentially five) and the Agreement would be sealed or unsealed upon approval.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Authority to approve and stay the case | Court has inherent authority to review fairness and approve settlement. | Court involvement should be limited; private settlement should largely proceed without extensive judicial intervention. | Court may approve and stay the case if the Agreement is fair. |
| Fairness, reasonableness, and adequacy of the settlement | Settlement reached after arm's-length negotiations; presumption of reasonableness applies. | Disputes over severity and scope of reforms; may challenge reasonableness. | Settlement is fair, reasonable, and adequate. |
| PLRA implications of approving a stay and retention of jurisdiction | PLRA not implicated because no prospective relief is ordered now. | Unclear implications; potential for future compliance orders to be subject to PLRA standards. | PLRA § 3626(a)(1)(A) is not implicated because no relief is ordered at this time. |
| Discretion/duty to evaluate settlement given nonparties' rights | Court must assess fairness due to effects on mentally ill inmates not parties to the settlement. | Settlement should be treated like ordinary private settlement to minimize judicial intrusion. | Court may exercise discretion to evaluate fairness prior to approval; it is appropriate here. |
Key Cases Cited
- Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (U.S. 1994) (retention of jurisdiction to enforce private settlement after dismissal)
- Landis v. North American Co., 300 U.S. 251 (U.S. 1936) (power to stay proceedings incidental to docket control)
- Lehman v. Revolution Portfolio L.L.C., 166 F.3d 389 (1st Cir.1999) (administrative closings to manage moribund cases)
- In re Pharm. Indus. Average Wholesale Price Litig., 588 F.3d 24 (1st Cir.2009) (presumption of reasonableness for arm's-length settlements)
- Benjamin v. Fraser, 348 F.3d 35 (2d Cir.2003) (monitoring/remedies distinctions in PLRA context)
- Robidoux v. Rosengren, 638 F.3d 1177 (9th Cir.2011) (considerations for settlements involving minors/federal claims)