Thomas v. Chrysler Group LLC, 2:14-cv-00671

Plaintiff Damion L. Thomas sued following injuries sustained while retrieving a vehicle for defendant Carol M. Douglass on September 23, 2013.
Carol M. Douglass moved for a determination that her settlement with Thomas was made in good faith under Nevada Revised Statute § 17.245 and for an order barring further contribution or indemnity claims against her.
The proposed settlement amount was $35,000.
The court applied Nevada precedent and the multi-factor test used to assess "good faith" settlements (amount paid, allocation, insurance limits, defendant’s financial condition, and absence of collusion or fraud).
The court found no evidence of collusion or fraud and determined the settlement amount reasonably reflected Douglass’s proportionate share of liability.
The court ordered the settlement declared in good faith under NRS 17.245, barred further contribution/equitable indemnity claims against Douglass, and directed the clerk to close the case.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the settlement between Thomas and Douglass is a "good faith" settlement under NRS 17.245, thereby barring further contribution or indemnity claims against Douglass	The $35,000 settlement is a proper resolution and should be approved as good faith	The settlement is within Douglass’s proportionate share, non-collusive, reasonable, and thus entitled to protection under NRS 17.245	The court held the $35,000 settlement is in good faith, found no collusion or fraud, and barred further contribution/equitable indemnity claims against Douglass

Veliscol Chem. Corp. v. Davidson, 811 P.2d 561 (Nev. 1991) (noting NRS 17.245 provides little guidance and courts apply multi-factor good-faith test)
In re MGM Hotel Fire Litig., 570 F. Supp. 913 (D. Nev.) (articulating factors used to evaluate good-faith settlements under NRS 17.245)
River Garden Farms, Inc. v. Superior Court, 26 Cal. App. 3d 986 (discussing factors for assessing collusion and fairness in settlements)