Carisa Coffman v. Theodore Brown, Toyota Material Handling Midwest, Inc. (mem. dec.)
48A04-1608-CT-1975
| Ind. Ct. App. | Feb 8, 2017Background
- On July 10, 2013 Coffman was injured in a car collision with Brown, who was working for Toyota Material Handling Midwest, Inc. at the time.
- Coffman sued Brown and Toyota (and initially an insurer that was later dismissed); the court-ordered mediation took place December 19, 2014.
- At mediation the parties signed a brief written settlement: payment of $17,500, plaintiff to pay listed liens and hold defendants harmless, and each side to split mediation costs.
- After mediation Toyota sent a settlement check but negotiations continued over a separate release; Coffman refused certain release language (a denial-of-liability clause).
- Coffman moved to set aside the settlement arguing a mutually agreeable release was a condition precedent or mutual mistake; Toyota moved to enforce the settlement and later offered to remove the disputed denial clause.
- The trial court enforced the December 19 settlement (ordering the parties to file a dismissal stipulation); Coffman appealed and the appellate court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the December 19, 2014 mediated agreement was enforceable | Coffman: No — enforceability depended on a mutually agreeable release; absent agreed release the settlement was an unenforceable agreement to agree | Toyota: Yes — the signed settlement set forth all essential terms (amount and lien allocation); a separate release was collateral and not a condition precedent | The court held the written settlement was an enforceable contract; the release was not an essential term and enforcement (dismissal stipulation) was proper |
Key Cases Cited
- Georgos v. Jackson, 790 N.E.2d 448 (Ind. 2003) (settlement agreements governed by contract principles and may be enforced)
- Wolvos v. Meyer, 668 N.E.2d 671 (Ind. 1996) (distinguishes unenforceable "agreement to agree" from enforceable agreements that sufficiently fix essential terms)
- MH Equity Managing Member, LLC v. Sands, 938 N.E.2d 750 (Ind. Ct. App. 2010) (court will enforce a reasonably definite settlement within its four corners)
- Sands v. Helen HCI, LLC, 945 N.E.2d 176 (Ind. Ct. App. 2011) (Indiana law favors enforcement of settlement agreements)
- Fackler v. Powell, 891 N.E.2d 1091 (Ind. Ct. App. 2008) (contract interpretation is a judicial function; unambiguous written terms control)