Erliying Soto v. C-Worthy Corp./Summit Holdings - Claims Center
206 So. 3d 117
| Fla. Dist. Ct. App. | 2016Background
- Claimant and Employer/Carrier (E/C) mediated a workers’ compensation dispute and executed a written mediation settlement agreement requiring Claimant to "execute a general release and resignation in favor of the employer."
- E/C prepared post-mediation paperwork that added several "indemnify and hold harmless" provisions not in the written settlement.
- Claimant and his attorney struck the indemnification provisions and returned the signed paperwork to E/C.
- E/C then backed out of the settlement; Claimant filed a motion to enforce the settlement and for approval of attorney’s fees and child-support allocation; JCC held an evidentiary hearing.
- JCC denied Claimant’s motion, finding no meeting of the minds because indemnification (as included in the post-mediation paperwork) was an essential, unresolved term.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the mediation settlement is enforceable despite E/C adding indemnification language after signing | Soto: The written settlement was unambiguous and did not include indemnification; indemnification is distinct from a release and was not an essential term, so settlement should be enforced | E/C: Inclusion of indemnification in the final paperwork showed no meeting of the minds on an essential term, so no enforceable agreement | Court: Reversed JCC — indemnification was not part of the unambiguous settlement, its later insertion was a new offer rejected by Claimant, so original settlement is enforceable |
Key Cases Cited
- Chubb Group Ins. Co. v. Easthagen, 889 So. 2d 112 (Fla. 1st DCA 2004) (JCC’s province to determine whether settlement reached and its terms)
- Robbie v. City of Miami, 469 So. 2d 1384 (Fla. 1985) (settlement agreements governed by contract rules; objective external manifestations control)
- Blackhawk Heating & Plumbing Co. v. Data Lease Fin. Corp., 302 So. 2d 404 (Fla. 1974) (contract formation depends on agreement of external signs)
- Crawford v. Barker, 64 So. 3d 1246 (Fla. 2011) (clear, unambiguous contract terms control; intent gleaned from four corners)
- Risco USA Corp. v. Alexander, 91 So. 3d 870 (Fla. 1st DCA 2012) (de novo review where interpretation of written document required)
- Bonagura v. Home Depot, 991 So. 2d 902 (Fla. 1st DCA 2008) (post-settlement paperwork adding unnegotiated release terms is outside original agreement and may constitute a new offer)