William Scott v. Brad Livingston, 628 F. App'x 900

William Scott, a Jehovah’s Witness and Texas prison inmate, sued TDCJ claiming unconstitutional/statutory denial of adequate religious services; district court treated claims under RLUIPA and the First Amendment.
While litigation proceeded Scott was transferred, placed in a treatment program, released on parole, then re-incarcerated; during his parole he entered settlement negotiations with TDCJ.
In February 2013 Scott signed a written agreement stating TDCJ would pay $3,000 in exchange for a full and final release and dismissal with prejudice; the document was filed in the district court record.
The district court declined to enforce the settlement, reached the merits, and held for Scott on the underlying claims.
On appeal TDCJ argued (1) Scott’s claims were moot due to settlement and transfer, and (2) the February 2013 written agreement was a binding settlement.
The Fifth Circuit concluded the February 2013 agreement was a valid, complete settlement under Texas law, vacated the district court judgment, and remanded with instructions to enforce the settlement and dismiss the case.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the February 2013 document constituted a binding settlement	Scott says he intended it as a preliminary agreement, not final	TDCJ says the written, signed agreement with price and release is a final settlement	Court: Binding settlement under Texas law; agreement contains essential terms
Whether subjective intent defeats objective contract language	Scott argues he did not intend to be bound	TDCJ points to clear, unambiguous wording evidencing objective intent	Court: Objective intent governs; plain language controls; subjective belief irrelevant
Whether form/labels (affidavit, "witnessed" signatures) or approval conditions negate contract	Scott contends form and signature wording show lack of TDCJ intent; approval by AG/Governor/Comptroller means not final	TDCJ argues form/labels irrelevant; approval language is a condition precedent, not lack of intent	Court: Form/labels do not negate intent; approval clause is a condition precedent and does not negate binding nature
Whether omitted terms (review of administrative directive; payment mechanics) render agreement incomplete	Scott says missing operational terms mean essential terms omitted	TDCJ says settlement contains essential price and release terms; other items not included and not required	Court: Agreement unambiguous and enforceable as written; cannot add terms by parol evidence

Cerda v. 2004-EQR1 L.L.C., 612 F.3d 781 (5th Cir.) (standard of review: legal conclusions de novo, factual findings for clear error)
White Farm Equip. Co. v. Kupcho, 792 F.2d 526 (5th Cir.) (settlement agreement = contract governed by state contract law)
Cedyco Corp. v. PetroQuest Energy, LLC, 497 F.3d 485 (5th Cir.) (conditional approvals can be treated as conditions precedent)
Padilla v. LaFrance, 907 S.W.2d 454 (Tex.) (price and release are key components of settlement agreements)
Gen. Metal Fabricating Corp. v. Stergiou, 438 S.W.3d 737 (Tex. App.) (agreement containing essential terms is binding; omission makes it an agreement to agree)
J.M. Davidson, Inc. v. Webster, 128 S.W.3d 223 (Tex.) (contract interpretation limited to four corners when unambiguous)
Addicks Servs. v. GCP-Bridgeland, LP, 596 F.3d 286 (5th Cir.) (courts limit interpretation to plain language of unambiguous contracts)
CherCo Props., Inc. v. Law, Snakard & Gambill, P.C., 985 S.W.2d 262 (Tex. App.) (discussion of essential terms in settlements)
Friends of the Earth, Inc. v. Laidlaw Envtl. Servs. (TOC), Inc., 528 U.S. 167 (U.S.) (settlement generally moots a case by eliminating a continuing interest)