McDonald v. Kansas City Southern Railway Company, 2:16-cv-15975

Johnnie McDonald worked for Kansas City Southern Railway (KCS) from 1970–2005; his widow Sharon McDonald sued under FELA after his death from cancer alleging workplace exposure.
Prior to suit, a KCS employee emailed to confirm a verbal agreement to settle "all claims" for a gross amount of $135,000.00.
Sharon McDonald replied by email: "This is acknowledgement of receipt of the proposed settlement of $135,000.00 in which I accept."
No formal release was ever signed; McDonald later attempted to reject the settlement and filed suit in October 2016.
KCS moved to dismiss (or alternatively for summary judgment) arguing the written emails established a binding settlement; the Court converted the motion to summary judgment and denied McDonald’s Rule 56(d) discovery continuance request.
The Court held the emails manifested mutual assent and enforced the settlement, dismissing McDonald’s claims with prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a binding settlement was formed	McDonald says agreement was preliminary and required a signed formal release	KCS says email confirmation plus McDonald’s emailed acceptance manifest mutual assent to settle for $135,000	Court: Binding settlement formed by the parties’ emails; dismissal granted
Whether absence of a signed release voids agreement	McDonald contends lack of signature means no contract	KCS contends parties can form binding agreement without later-signed formal release unless parties explicitly made execution a condition	Court: Agreement enforceable despite no signed final release absent an explicit condition precedent
Whether the dispute required a jury	McDonald requests jury to decide existence of settlement	KCS says formation is a legal question for the court where writings are unambiguous	Court: No jury needed because writings unambiguously show assent; court decides as matter of law
Whether additional discovery should be allowed under Rule 56(d)	McDonald sought more time/discovery to oppose summary judgment	KCS opposed; court required affidavit/specification of needed facts	Court: Denied Rule 56(d) request for lack of affidavit and failure to specify what discovery would create a genuine issue

Dice v. Akron, C. & Y. R. Co., 342 U.S. 359 (U.S. 1952) (jury right under FELA acknowledged but parties may settle)
In re Deepwater Horizon, 786 F.3d 344 (5th Cir. 2015) (settlements enforceable absent explicit condition that formal execution is required)
Guidry v. Halliburton Geophysical Servs., Inc., 976 F.2d 938 (5th Cir. 1992) (settlement agreements are contracts; interpretation is question of law when unambiguous)
Celotex Corp. v. Catrett, 477 U.S. 317 (U.S. 1986) (summary judgment burden-shifting principles)
Good v. Pennsylvania R. Co., 384 F.2d 989 (3d Cir. 1967) (oral/unsigned settlement binding despite later refusal to sign formal release)
Callen v. Pennsylvania R. Co., 332 U.S. 625 (U.S. 1948) (releases by railroad employees governed like releases of others)