Stone Creek Custom Kitchens & Design v. Vincent, K16A-01-002 WLW

Dispute arose from prior proceedings in Justice of the Peace Court, Court of Common Pleas, and this Superior Court appeal concerning alleged claims and counterclaims between Stone Creek (defendant/appellant) and Joseph & Danielle Vincent (plaintiffs/appellees).
On Sept. 21, 2016 counsel for Stone Creek sent an offer letter proposing to fully resolve the dispute for $5,500, with a deadline to accept by Sept. 22, 2016 at 2:00 p.m.; the letter stated Stone Creek admitted no liability and that a formal settlement agreement would follow.
The Vincents accepted the offer by email/telephone; Stone Creek counsel represented a formal agreement and draft would follow and asked the court to continue oral argument based on the parties reaching an agreement in principle.
Stone Creek later delayed producing a draft; when a draft was emailed it included a proposed installment payment schedule which the Vincents rejected; Stone Creek argued timing of payment was a material term not agreed to.
The Vincents moved to enforce the settlement; Stone Creek conceded agreement on amount but contended absence of a timing term prevented contract formation under the mirror-image rule.
The Court found a binding settlement for $5,500 existed based on offer and acceptance, supplied a reasonable time for payment (payment in a reasonable time, not installments), granted the Vincents’ motion to enforce, and denied Stone Creek’s motion for reargument as moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a binding settlement agreement was formed	Vincents: Stone Creek's Sept. 21 offer and plaintiffs' acceptance created a binding contract	Stone Creek: Omitted timing-of-payment was material; without it no contract under mirror-image rule	Court: Valid settlement formed (offer + acceptance); timing was not a material term
Whether the timing of payment is an essential term preventing enforcement	Vincents: Timing was not previously negotiated and thus not material; acceptance bound Stone Creek to pay $5,500	Stone Creek: Payment timing was material and unresolved, so no meeting of minds	Court: Timing was not material; court will supply a reasonable time for payment
Whether a later draft proposing installment payments modified the agreement	Vincents: Draft adding installment schedule was a unilateral attempt to change terms and was rejected	Stone Creek: Draft evidence of intended payment schedule and subsequent negotiations	Court: No evidence of agreed modification; installment proposal was not part of the contract
Relief available to plaintiff	Vincents: Court should enforce settlement and order payment of $5,500 within a reasonable time	Stone Creek: No enforceable obligation absent agreed payment term	Court: Granted motion to enforce; ordered settlement for $5,500 payable within a reasonable time; denied Stone Creek’s reargument motion as moot

Carlson v. Hallinan, 925 A.2d 506 (Del. Ch. 2006) (elements required to enforce settlement agreements)
Loppert v. Windsortech, Inc., 865 A.2d 1282 (Del. Ch. 2004) (objective manifestations govern intent to be bound; nonessential terms may be left for later negotiation)
Martin v. Star Publ'g Co., 126 A.2d 238 (Del. 1956) (if no time for performance is fixed, court will imply a reasonable time)