Shoals v. Owens & Minor Distribution, Inc., 2:18-cv-02355-WBS-JDP

Marcus Shoals, a former Staffmark Investment temporary employee, sued Owens & Minor (O&M), John Cline, Staffmark Investment, and Staffmark Holdings alleging racial discrimination, sexual harassment, retaliation, and related FEHA/Title VII claims.
Case was removed to federal court; the court compelled arbitration and Shoals proceeded through JAMS; Staffmark Holdings was dismissed after arbitration.
Shoals served a CCP § 998 statutory offer for $110,000 on Staffmark Investment; the parties later settled for $70,000 and executed a release, dismissal-without-prejudice as to Staffmark Investment, mutual waiver of fees, and a § 1542 waiver; no admission of liability.
Staffmark Investment moved for a judicial determination that the settlement was made in good faith under Cal. Civ. P. § 877.6; the motion was unopposed by the remaining non-settling defendants (O&M and Cline).
The court evaluated the Tech-Bilt factors (approximate total recovery and settlor liability, settlement amount, allocation, discount for settlement, insurance/financials, and collusion) and found the $70,000 settlement was within the reasonable range and negotiated at arm’s length.
The court granted the motion: the settlement is in good faith, bars contribution/indemnity claims arising from the complaint, dismisses Shoals’ complaint without prejudice as to Staffmark Investment, and orders each party to bear its own fees and costs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the settlement between Shoals and Staffmark Investment is a "good faith" settlement under Cal. Civ. P. § 877.6	$70,000 settlement is an acceptable resolution of Shoals’ claims (original offer $110,000)	Staffmark asserts no liability but settled to avoid litigation costs; settlement reached at arm’s length	Court: $70,000 is within the reasonable range of Staffmark’s proportionate liability and is a good-faith settlement under Tech-Bilt
Effect of a good-faith finding on contribution/indemnity claims and case posture	Settlement should resolve claims against Staffmark and is entitled to statutory protections	A good-faith settlement should bar future contribution/indemnity claims and permit dismissal as to settling party	Court: Finding bars any claims for contribution/indemnity arising from the complaint and dismisses Shoals’ complaint without prejudice as to Staffmark Investment

Tech-Bilt, Inc. v. Woodward-Clyde & Associates, 38 Cal. 3d 488 (1985) (sets factors and standard for determining good-faith settlement under Cal. Civ. P. § 877.6)
Fed. Sav. & Loan Ins. Corp. v. Butler, 904 F.2d 505 (9th Cir. 1990) (substantive California settlement law applies in federal actions even when procedural mechanisms differ)