Roland Chalifoux, Jr. v. Wetzel County Hospital, Inc.
24-1108
4th Cir.Jul 8, 2025Background
- Dr. Roland Chalifoux, an osteopathic physician, had his privileges revoked at Wetzel County Hospital (WCH) after an internal investigation raised concerns about patient safety during a procedure.
- WCH reported the revocation to the National Practitioner Data Bank (NPDB) and the West Virginia Board of Osteopathic Medicine; the latter dismissed its complaint, but hospital privileges were not reinstated.
- Dr. Chalifoux sued WCH alleging antitrust violations, defamation, tortious interference, due process violations, and conspiracy.
- The parties reached agreement on non-economic settlement terms; Dr. Chalifoux, through counsel, subsequently made a bracketed $200,000-$400,000 cash demand, with $300,000 as midpoint.
- WCH accepted the $300,000 demand and non-economic terms, but Dr. Chalifoux refused to sign, claiming the offer was withdrawn and disputing counsel's authority to settle.
- The district court granted WCH's motion to enforce the settlement agreement; Dr. Chalifoux appealed, challenging the existence and enforceability of the settlement and the scope of his attorney's authority.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Requirement of Plenary Evidentiary Hearing | Hearing was insufficient; plaintiff couldn’t testify | Full hearing was held, evidence considered | Hearing adequate; no error |
| Attorney’s Authority to Settle | Kaminski lacked authority; no meeting of minds | Kaminski had apparent authority; conduct supported | Kaminski had apparent authority to settle |
| NPDB Report as Condition of Settlement | Removal of NPDB report was a condition precedent | No such term agreed to, and voiding was impossible | Removal not a settlement term; legal impossibility |
| Sanctions/Confidentiality of Settlement Terms | Disclosure justified voiding the agreement | No applicable argument; plaintiff didn’t request below | Not considered—new on appeal, no exceptional circumstances |
Key Cases Cited
- Hensley v. Alcon Labs., Inc., 277 F.3d 535 (4th Cir. 2002) (district courts have inherent authority to enforce settlement; must find agreement and ascertainable terms)
- Smith-Phifer v. City of Charlotte, 118 F.4th 598 (4th Cir. 2024) (motions to enforce settlement require finding of complete settlement, factual disputes may require hearing)
- Auvil v. Grafton Homes, Inc., 92 F.3d 226 (4th Cir. 1996) (attorneys lack implied authority to settle without clear client authorization)
- Krakauer v. Dish Network, L.L.C., 925 F.3d 643 (4th Cir. 2019) (scope of agency is a question of fact)
- Giovani Carandola, Ltd. v. Bason, 303 F.3d 507 (4th Cir. 2002) (findings about agency relationship reviewed for clear error)