Turner v. Archer Western Company, 1:17-cv-02228

Steven Turner sued Archer Western in state court alleging defendant sprayed hazardous chemicals that damaged his two vehicles and caused medical injuries; defendant removed to federal court on diversity grounds.
After extensive briefing, the court granted summary judgment to Archer Western on Turner’s medical/health claim for lack of causation but denied summary judgment on Turner’s property-damage claim (vehicles remained); only the property claim survived.
Parties engaged in settlement communications for the remaining property claim; Archer Western offered to pay $8,968.42 (the exact Maaco repair estimate) and sent Turner a general release and stipulation of dismissal for signature.
Turner signed, notarized, and mailed the release (postmarked Jan. 23, 2019); he left a voicemail on Jan. 25, 2019 saying he changed his mind, but the signed release had already been dispatched.
Turner later claimed the settlement was the result of trickery/duress because it did not compensate his medical claims; Archer Western moved to enforce the settlement and the court held an evidentiary hearing.
The court found (based on testimony and documentary evidence) that an enforceable settlement contract was formed under Maryland law and denied Turner’s rescission arguments (fraud, negligent misrepresentation, unconscionability).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a binding settlement was formed	Turner contends he was tricked and revoked acceptance before contract formation	Turner signed, notarized, and mailed the release before revocation; mailbox rule makes acceptance effective upon mailing	Court held a valid, enforceable settlement existed (mailbox rule applied)
Whether the settlement is voidable for fraud or fraudulent inducement	Turner asserted he was misled because settlement did not cover medical claims	Archer Western said it never represented it would pay medical damages; offer always limited to property damage	Court found no evidence of intentional misrepresentation; fraud not proven
Whether negligent misrepresentation supports rescission	Turner argued he relied on counsel’s representations to his detriment	Archer Western maintained it consistently offered only property-damage recovery and Turner knew the summary judgment outcome	Court found no material misrepresentation and no justifiable reliance warranting rescission
Whether the settlement is unconscionable or entered under duress	Turner claimed procedural and substantive unconscionability due to his being self-represented and injured	Archer Western argued communications were by phone/mail, amount matched Turner’s claimed damages, and Turner was competent (notarized)	Court held no procedural or substantive unconscionability; settlement enforced

Hensley v. Alcon Labs., Inc., 277 F.3d 535 (4th Cir. 2002) (district courts have inherent authority to enforce settlement agreements)
Williams v. Prof’l Transp., Inc., 388 F.3d 127 (4th Cir. 2004) (motions to enforce settlements draw on contract principles)
Swift v. Frontier Airlines, Inc., 636 F. App’x 153 (4th Cir. 2016) (if factual disputes over existence/terms exist, hold evidentiary hearing; otherwise court may summarily enforce)
Klaxon Co. v. Stentor Elec. Mfg. Co., 313 U.S. 487 (choice-of-law in diversity cases follows forum state law)