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Sturgis v. Author Solutions, Inc.

Citation: 317 F. App'x 553Docket: No. 08-2369

Court: Court of Appeals for the Seventh Circuit; March 24, 2009; Federal Appellate Court

Narrative Opinion Summary

In a diversity lawsuit, the plaintiff alleged breach of contract and fraud against a publishing company and its executives. The district court granted summary judgment to the defendants, citing a Release and Settlement Agreement signed by the plaintiff, which barred his claims. The agreement had resolved previous disputes over royalties and included a payment to the plaintiff. Despite the plaintiff's assertions of improper marketing and fraud, he failed to provide evidence disputing the agreement's validity or seeking its rescission. The court also awarded the defendants attorneys' fees, as the plaintiff breached the agreement by litigating the claims it covered. On appeal, the plaintiff argued forgery, claiming he had not signed the release, but failed to substantiate this. The court upheld the summary judgment, finding the plaintiff's claims fell within the release's scope and noting his acceptance of the settlement terms. The plaintiff's motion for reconsideration, including a new copyright claim, was denied for lack of specific errors. The court's decisions, including the awarding of attorneys' fees, were affirmed, allowing the defendants to seek additional fees incurred during the appeal.

Legal Issues Addressed

Assent to Contract Terms

Application: Sturgis's actions, including signing the release and cashing the settlement check, demonstrated his intent to be bound by the agreement under Indiana law.

Reasoning: The record indicates that Sturgis initially proposed settlement terms accepted by AuthorHouse, which included him signing and later cashing a check for $1,699 without disputing the validity of his signature.

Awarding of Attorneys' Fees

Application: The court justified awarding attorneys' fees to AuthorHouse, as Sturgis violated the release agreement by pursuing litigation.

Reasoning: He contested the awarding of attorneys’ fees to AuthorHouse but did not demonstrate how the court abused its discretion; the fees were justified since Sturgis violated the release agreement by suing AuthorHouse.

Enforceability of Release and Settlement Agreements

Application: The court ruled that the Release and Settlement Agreement signed by Sturgis barred his claims against AuthorHouse, as he did not provide evidence to counter its validity.

Reasoning: The district court granted summary judgment to AuthorHouse, determining that Sturgis’s claims were barred by a Release and Settlement Agreement executed in June 2006, which Sturgis signed.

Scope of Release Agreements

Application: The court found that Sturgis's claims of breach of contract and fraud were within the scope of the release, as they arose from the publishing contracts covered by the agreement.

Reasoning: Sturgis claimed that his breach of contract and fraud allegations fell outside the release's scope; however, the court determined that his grievances arose from the publishing contracts, which were covered by the release.

Summary Judgment Standards

Application: Sturgis failed to present evidence to show a genuine issue for trial, relying instead on unsubstantiated allegations.

Reasoning: Sturgis failed to provide sufficient evidence to counter the summary judgment, relying solely on unsubstantiated allegations.