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Hadwari v. Keystone Shipping Co.

Citations: 762 F. Supp. 426; 1991 A.M.C. 2395; 1991 U.S. Dist. LEXIS 6080; 1991 WL 70646Docket: Civ. A. No. 89-1639-N-A

Court: District Court, D. Massachusetts; April 24, 1991; Federal District Court

Narrative Opinion Summary

In this case, the plaintiff moved to enforce a settlement agreement which the defendant opposed, contending that the agreement was contingent on the approval of the defendant's insurer's board of directors, who subsequently disapproved it. Initially set for trial on March 11, 1991, the trial was postponed due to the plaintiff's illness. On March 14, both parties informed the court of an agreed settlement, leading to the dismissal of the case without costs and the discharge of the jury, with a provision for reopening within 60 days if the settlement was not finalized. The disagreement arose when the defendant's insurer disapproved the settlement, prompting the plaintiff to seek a ruling that the settlement was unconditional. The court found no evidence that the settlement was conditional and highlighted the actions taken during court proceedings as contradicting a conditional agreement, applying judicial estoppel principles to preclude the defendant's claims. Consequently, the court revoked the dismissal, upheld the settlement, and ordered judgment for the plaintiff in the amount of $176,000, with interest accruing from March 14, 1991. The court noted the defendant did not dispute its counsel's authority to settle, thereby reaffirming the enforceability of the settlement agreement.

Legal Issues Addressed

Authority of Counsel to Settle

Application: The court noted the defendant did not dispute its counsel's authority to settle, reaffirming the validity of the settlement agreement.

Reasoning: The defendant did not dispute its counsel's authority to settle; however, the court noted that if such a claim were made, it would reopen the order for further hearing.

Enforcement of Settlement Agreements

Application: The court enforced the settlement agreement as unconditional because the term 'settlement' was not explicitly stated as conditional during the court proceedings.

Reasoning: The court found that the term 'settlement' was not expressed as conditional in its presence and that there was no indication of a known custom regarding such conditions.

Judicial Estoppel

Application: The defendant was precluded from asserting the settlement was conditional due to the principles of judicial estoppel, as their actions during court proceedings suggested otherwise.

Reasoning: The court emphasized that the dismissal of the case and discharge of the jury contradicted the notion of a conditional settlement. The defendant is estopped from claiming otherwise due to judicial estoppel principles.