YOLANDA MEDRANO V. ROBERT C. RUGELIS (L-3875-18, HUDSON COUNTY AND STATEWIDE), A-1278-20

Medrano filed a personal-injury suit after being struck in a crosswalk; her then-counsel sent demand letters seeking $250,000 but Medrano says she later insisted on $500,000.
Between July and September 2019, negotiations occurred; the paralegal for Medrano’s lawyer emailed defense counsel on Sept. 1 indicating a $250,000 position.
On Sept. 16, defense counsel and Medrano’s then-counsel purportedly agreed to settle for $250,000 and defense counsel confirmed by email; a release was later sent but Medrano never signed it.
Medrano certified she never authorized a $250,000 settlement and that the paralegal was not empowered to make that counteroffer; neither her former lawyer nor the paralegal submitted certifications.
A motion judge enforced the alleged settlement without a plenary hearing; Medrano retained new counsel and moved to vacate under Rule 4:50-1.
The Appellate Division found Medrano’s certifications raised material factual disputes about counsel’s authority and reversed, remanding for a plenary hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there an enforceable settlement for $250,000?	No — Medrano never authorized that amount.	Yes — counsel agreed Sept. 16 and defense counsel’s confirming email and release show settlement.	Court: disputed material facts exist; cannot enforce without plenary factfinding; remand.
Did the attorney/paralegal have actual authority to settle at $250,000?	No — Medrano told paralegal and counsel she wanted $500,000; no express authorization.	Counsel’s negotiations and communications demonstrate authority to settle.	Court: Medrano’s certifications raise a material issue; hearing required to determine actual authority.
Can apparent authority be established solely by the attorney’s words/actions?	No — apparent authority must be shown by the client’s words or conduct, not just the attorney’s.	Attorney communications and conduct suffice to create reasonable belief of authority.	Court: attorney’s acts alone are insufficient; apparent authority requires client-derived indications; dispute requires hearing.
Was the motion judge justified in resolving the dispute without a plenary hearing?	No — conflicting affidavits create a genuine issue of material fact needing a hearing.	Yes — evidence was straightforward and established settlement as a matter of law.	Court: standard is like summary judgment; here competent evidence raises factual disputes, so a plenary hearing is required.

Nolan v. Lee Ho, 120 N.J. 465 (1990) (settlement agreements are contracts)
Amatuzzo v. Kozmiuk, 305 N.J. Super. 469 (App. Div. 1997) (plenary hearing required when there is a genuine dispute about attorney authority to settle)
U.S. Plywood Corp. v. Neidlinger, 41 N.J. 66 (1963) (attorney negotiations are not binding absent client authorization or a reasonable basis to presume authority)
Jennings v. Reed, 381 N.J. Super. 217 (App. Div. 2005) (party claiming lack of authority bears a heavy burden)
Brill v. Guardian Life Ins. Co., 142 N.J. 520 (1995) (standard for resolving factual disputes analogous to summary judgment)
Harrington v. Harrington, 281 N.J. Super. 39 (App. Div. 1995) (trial courts cannot resolve material factual disputes on conflicting affidavits)