K.C. v. Torlakson

A federal court will have the discretion to exercise ancillary jurisdiction over a motion to enforce attorney’s fees in a matter that is related to, but may be separate from, a federal lawsuit, even if such lawsuit has concluded.

The plaintiffs include four students who previously filed and settled a class action lawsuit against the defendants, which include representatives of California Public Schools. The lawsuit concerned the defendants’ failure to provide necessary services for students with diabetes. The settlement agreement allowed the district court to retain jurisdiction for two and one-half years, a limit which ended on January 24, 2010. In November 2011, the plaintiffs filed a motion in order to collect attorney’s fees incurred in monitoring the enforcement of the settlement agreement, pursuant to 42 U.S.C. § 12205, Section 504, 29 U.S.C. § 794a(b), and 20 U.S.C. § 1415(i)(3)(B). The defendants’ argued that the district court did not have jurisdiction for this matter because its jurisdiction to enforce the settlement agreement already ended. The Ninth Circuit held that ancillary jurisdiction may be exercised over collateral proceedings, such as this. The purpose of such “ . . . is to enable a federal court to render a judgment that resolves the entire case before it and to effectuate its judgment once it has been rendered.” While the district court’s jurisdiction to enforce the settlement agreement no longer applies, its ancillary jurisdiction over attorney’s fees collateral to the underlying dispute still applies because “such ancillary jurisdiction exists even after the underlying litigation has concluded.” In other words, “no Article III case or controversy is needed with regard to attorney’s fees . . . because they are but an ancillary matter over which the district court retains equitable jurisdiction even when the underlying case is moot.” Since the plaintiffs are seeking attorney’s fees under federal law, and not through a breach of contract claim, pursuant to case law and the purpose of ancillary jurisdiction, the district court has jurisdiction over such motion. REVERSED and REMANDED.