In the Matter of the Complaint of Archer Daniels Midland Company and American River Transportation Company LLC for Exoneration from, or Limitation of, Liability

Filing 61

ORDER. It is hereby ordered that the Court will take no action on 59 Consent Motion for Entry of Final Decree of Exoneration from Liability (Written Opinion). Signed by Judge Wilhelmina M. Wright on 8/9/2019. (RJE)

UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA

In the Matter of the Complaint of Archer
Daniels Midland Company and American
River Transportation Company LLC for
Exoneration from, or Limitation of,
Liability,

Case No. 18-cv-1131 (WMW/SER)

ORDER

Petitioner.

This matter is before the Court on the July 30, 2019 Consent Motion for Entry of
Final Decree of Exoneration from Liability. (Dkt. 59.) Petitioners Archer Daniels Midland
Company and American River Transportation Company LLC—with the consent of
Claimant Union Pacific Railroad Company and third-party Defendant Upper River
Services, LLC—seek a final decree of exoneration from liability.
The settlement of a lawsuit between private parties ordinarily is solely in the
province of the parties and need not be approved by a district court. See Gardiner v. A.H.
Robins Co., 747 F.2d 1180, 1189 (8th Cir. 1984). “[F]ederal courts have neither the
authority nor the resources to review and approve the settlement of every case brought in
the federal court system.” Caplan v. Fellheimer Eichen Braverman & Kaskey, 68 F.3d 828,
835 (3d Cir. 1995). In fact, “[c]ourts not only frown on interference by trial judges in
parties’ settlement negotiations, but also renounce the practice of approving parties’
settlement agreements.” Gardiner, 747 F.2d at 1189 (citing United States v. City of Miami,
614 F.2d 1322, 1330 (5th Cir. 1980)). When the parties agree, they may settle their
litigation at any time; the court need not be involved. Id.

It is an exceptional circumstance, not the general rule, for a district court to approve
the adequacy of a settlement. City of Miami, 614 F.2d at 1331. For instance, entry of a
stipulated dismissal under Rule 41(a)(1)(ii) is effective automatically and does not require
approval by a district court. See Fed. R. Civ. P. 41(a)(1)(A)(ii). The same is true of an
entry of judgment pursuant to an offer of judgment under Rule 68. See Fed. R. Civ. P.
68(a); see also White v. Nat’l Football League, 756 F.3d 585, 595 (8th Cir. 2014)
(observing that, under Rule 68, “the clerk enters judgment in the amount stipulated,” and
does so “without any involvement by the court”).
The present motion memorializes an agreement between private parties resolving
this litigation. The parties provide no legal authority addressing the need for or propriety
of obtaining the Court’s approval of or substantive involvement in any aspect of their
agreement. Because there appears to be no legal basis for submitting the final decree of
exoneration from liability to the Court for approval, the Court declines to provide its
endorsement.
ORDER
Based on the foregoing analysis, the Court will take no action on the Consent
Motion for Entry of Final Decree of Exoneration from Liability, (Dkt. 59).

Dated: August 9, 2019

s/Wilhelmina M. Wright
Wilhelmina M. Wright
United States District Judge

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