Suzette Eaton v. FCA US LLC

Summary

The United States District Court for the Central District of California declined to immediately enter judgment under Federal Rule of Civil Procedure 68 in a Song-Beverly Consumer Warranty Act action. The court ordered the parties to show cause why a single judgment including attorney's fees and costs should not be entered, set a deadline for resolving or briefing those issues, and warned that judgment would otherwise be entered for $60,791.68 without fees or costs.

Holdings

1. The court declined to enter judgment at that time because the Rule 68 offer contemplated that attorney fees, costs, and expenses could be determined by the court, and the action was subject to the Song-Beverly Act's provision allowing those amounts as part of the judgment.
2. The parties were ordered to show cause why a single judgment including the $60,791.68 payment and any awarded attorney fees and costs should not be issued.

Questions Presented

1. Whether the court should enter judgment under Federal Rule of Civil Procedure 68(a) before determining the attorney fees and costs recoverable under the Song-Beverly Consumer Warranty Act.
2. Whether a single judgment should include both the $60,791.68 compromise payment and any attorney fees and costs awarded by the court.

Disposition

other