2:23-cv-00530
E.D. Va.Feb 7, 2025Background
- Plaintiff Jazmyn Hasan, a former Sentara employee, filed suit alleging violations of the ADA (failure to accommodate, wrongful termination) and the FMLA (unlawful retaliation).
- After the Court dismissed two of Hasan’s claims and let the FMLA retaliation claim proceed, the parties engaged in settlement negotiations.
- On October 7, 2024, Hasan’s counsel, with her express authorization, communicated a final settlement offer to Sentara; Sentara accepted and standard settlement terms were discussed.
- Subsequent emails confirm Hasan’s agreement to the settlement terms, and both parties prepared to file a notice of settlement with the Court.
- Before the agreement was formally executed, Hasan sought to revoke her acceptance and her attorney moved to withdraw, which the Court permitted after further proceedings.
- Sentara moved to enforce the settlement agreement; a hearing was held, and the Court found the agreement enforceable.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was a binding settlement agreement reached? | Hasan claims she revoked acceptance before execution. | Sentara: All material terms agreed; acceptance was clear and authorized. | Complete settlement reached; Hasan’s intent was objectively manifested. |
| Were the terms of the agreement definite? | Hasan raised concern over a Medicare provision; later tried to revoke agreement. | Sentara: Terms included standard provisions; no dispute on material terms. | Terms were sufficiently definite; eliminates Medicare clause concern. |
| Did Hasan's attorney have authority to settle? | Hasan implied doubts based on her mental state at acceptance. | Sentara: Attorney had both actual and apparent authority from Hasan. | Attorney had both actual and apparent authority to settle on Hasan’s behalf. |
| Could Hasan revoke the agreement due to mental state? | Hasan cited her mental health issues at the time of agreement. | Sentara: No evidence of incompetence; agreement made with capacity. | No evidence of incompetence; settlement remains binding. |
Key Cases Cited
- Hensley v. Alcon Labs., Inc., 277 F.3d 535 (4th Cir. 2002) (district courts have inherent authority to enforce settlements and must find a complete agreement with discernable terms)
- Moore v. Beaufort County, 936 F.2d 159 (4th Cir. 1991) (objective intent of parties governs whether binding settlement exists; counsel has apparent authority unless limited)
- Alexander v. Industries of the Blind, Inc., 901 F.2d 40 (4th Cir. 1990) (oral settlement agreements can be enforceable if intent to be bound is clear)
- Montagna v. Holiday Inns, Inc., 221 Va. 336 (Va. 1980) (essential contract elements are offer, acceptance, and consideration)
- Patel v. Barot, 15 F. Supp. 3d 648 (E.D. Va. 2014) (second thoughts or regret are not grounds to set aside a binding settlement by a competent party)