Richard Britton v. Swift Transportation Company, Inc.
Docket: 98-2492
Court: Court of Appeals for the Seventh Circuit; August 13, 1999; Federal Appellate Court
Swift Transportation Company appeals a district court's refusal to vacate its settlement with Richard Britton, an Illinois state trooper who received $450,000 following a personal injury claim related to a truck accident. Swift alleges that the settlement was obtained through fraud, asserting that Britton misrepresented his physical condition. Prior to the settlement, Britton was limited to light duty but was cleared to return to full duty the day after the settlement was finalized. The district court previously denied Swift's motion to vacate the judgment, a decision upheld by the appellate court, which found no abuse of discretion. However, the appellate court remanded the case for additional discovery due to concerns about the timing of Britton's return to full duties and his statements regarding his abilities. Upon further discovery, the district court again rejected Swift's request to vacate the settlement, finding no evidence that Britton was feigning his condition to secure the settlement. Swift's current appeal focuses on whether the new discovery has produced significant evidence warranting vacatur, reiterating that previous arguments based solely on the past record are not relevant since they have already been adjudicated. Swift presented evidence concerning Britton's intentions during the settlement process, focusing on statements made to Dr. Naddaf regarding Britton's physical limitations and pain since April 1995. Swift argued that Britton's return to work was not coincidental, highlighting his claims to an Illinois state police officer about always intending to return to work. Britton sought to settle the case to avoid a trial that could establish his full disability, which would prevent him from working. Evidence from Dr. Schweiber indicated that after the settlement, Britton requested a release to work without limitations, citing a promotion that entailed less patrol duty. Swift contended that Britton misrepresented his pain levels to Swift but possibly understated them to his doctor and employer to gain clearance to work. The district court reviewed this evidence and concluded it did not indicate fraud, finding that while Britton may have misled someone, it was equally plausible that he was minimizing his injuries. Testimonies from law enforcement personnel supported the view that Britton downplayed his condition to continue working. The court interpreted Britton's desire to settle as an attempt to keep his job, consistent with minimizing his injuries. Swift did not directly inquire about Britton’s future as a state trooper, leading to ambiguities in his statements. The district court favored the interpretation of minimizing his condition over evidence of fraud and found no abuse of discretion in its ruling. Consequently, the district court's decision was affirmed.