Knox v. County of Los Angeles – Case Brief Summary (California)

In Knox v. County of Los Angeles (1980) 109 Cal.App.3d 825, three plaintiffs sued a market and three of its employees (the market defendants) as well as three governmental defendants, for unlawful arrest and other causes of action, arising out of a single incident in which the plaintiffs were arrested by sheriff's deputies for allegedly violating a temporary restraining order regulating picketing. (Knox, supra, 109 Cal.App.3d at pp. 828-829.)

The plaintiffs reached a pretrial settlement with the market defendants amounting to $4,000 per plaintiff, for a total of $12,000. (Id. at pp. 829-830.) At trial, the governmental defendants were found liable for a total of $52,500 in damages. (Id. at pp. 830-831.)

Following trial, the court denied the governmental defendants' request for a $12,000 offset for the amount the three plaintiffs received in settlement from the market defendants. (Id. at p. 831.)

The reviewing court reversed and remanded for further proceedings to determine the amount of the offset to which the governmental defendants were entitled. (Knox, supra, 109 Cal.App.3d at p. 837.)

It explained, "the lower court should have required an evidentiary showing by plaintiffs establishing and justifying an agreed allocation of less than all of the $4,000 settlement figure to the first and second causes of action for unlawful arrest and false imprisonment in which the market defendants were alleged to be joint tortfeasors with the governmental defendants. Had such an allocation been shown, its effectiveness would depend upon finding it to be a good faith allocation. The statutory requirement of good faith extends not only to the amount of the overall settlement but as well to any allocation which operates to exclude any portion of the settlement from the setoff. It is apparent, therefore, that an evidentiary hearing is required to establish a factual basis, if any there is, for denying the governmental defendants credit for the full amount of the settlement." (Id. at pp. 836-837.)