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Adkins v. Morgan County

United States District Court, E.D. Tennessee

May 11, 2018

JAMES TRAVIS ADKINS, Plaintiff,
v.
MORGAN COUNTY, TENNESSEE, et al., Defendants.

          MEMORANDUM OPINION AND ORDER

          J. RONNIE GREER UNITED STATES DISTRICT JUDGE

         Plaintiff James Travis Adkins brought this civil rights case, 42 U.S.C. § 1983, for damages, alleging that he was denied medical care for serious medical needs, while he was incarcerated in the Morgan County jail in Wartburg, Tennessee [Doc. 35, Second Am. Comp.]. This matter is before the Court on a motion for partial final judgment filed by two Defendants, Lucinda Heidel and Southern Health Partners, Inc. (“SHP”) [Doc. 84]. The basis of the motion is that the parties reached an agreement to settle and resolve their claims against one another and that they signed a settlement agreement to that effect [Id.]. Plaintiff opposes the motion and seeks to have the Court set aside the settlement agreement [Doc. 88, sealed]. For reasons below, the Court will DENY Plaintiff's request and GRANT Defendants' dispositive motion.

         I.FACTUAL AND PROCEDURAL BACKGROUND

         As relevant here, Plaintiff sued Defendant Heidel, a licensed practical nurse employed by SHP, for being deliberately indifferent to his back and leg pain-Plaintiff later was diagnosed as having a spinal infection-in June and July of 2016 [Id. at ¶¶ 41-42]. Plaintiff sued Defendant SHP, Defendant Heidel's corporate employer, for its failure to train Defendant Heidel to respond appropriately to inmates' serious medical needs and not to respond to such needs with deliberate indifference [Id. at ¶¶ 7, 41-42]. Plaintiff sought ten million dollars ($10, 000, 000.00) in compensatory and punitive damages from Defendants [Id. at 8].

         After the parties were ordered to participate in mediation, the mediator reported to the Court that Plaintiff had settled his case against Defendants Heidel and SHP [Doc. 83]. Defendants Heidel and SHP filed a motion for partial final judgment based on that settlement [Doc. 84], supported by a copy of the settlement agreement [Doc. 86, sealed].[1] Plaintiff responded in objection to the motion and asked the Court to set aside the settlement agreement [Doc. 88, sealed].

         Plaintiff attacks the validity of the settlement agreement on four bases [Doc. 88]. First, Plaintiff argues that there was no meeting of the minds with respect to a material issue. Plaintiff points to an exchange of emails before and after the signing of the settlement agreement as objective acts by Plaintiff that demonstrate the lack of any meeting of the minds. Plaintiff next suggests that there was a mutual mistake as to a term in the settlement agreement. Both the mutual mistake as well as the lack of meeting of the minds arguments, as the Court interprets those arguments, center on what the mediator communicated to Plaintiff regarding his (the mediator's) understanding of the settlement.

         The third problem pointed to by Plaintiff is that the settlement agreement is ambiguous [Doc. 88]. The ambiguity, so argues Plaintiff, stems from obligations imposed on Defendants' counsel to prepare a formal mutual release of all claims and on the parties to execute the agreement. Finally, so argues Plaintiff, there was no consideration for the dismissal of his claims, and Plaintiff reasonably expected that such details would be included in the formal settlement agreement [Id.]. Defendant replied to Plaintiff's response and request to set aside mediated settlement and not surprisingly objects to Plaintiff's request [Doc. 90, sealed].

         On April 25, 2018, the motion for partial final judgment came before the Court for a hearing [Docket Entry of April 13, 2018]. For reasons set forth below, the Court will deny Plaintiff's request to set aside the settlement agreement, will enforce the signed settlement agreement as written, and will grant the motion for partial final judgment filed by Defendants Heidle and SHP.

         II. LAW AND ANALYSIS

         A. Enforcement of Settlement Agreements

         “A federal court has the inherent authority and equitable power to enforce agreements in settlement of litigation before it.” Rodgers v. Gorman-Rupp Co., 55 Fed.Appx. 319, 320 (6th Cir. 2003) (citing Brock v. Scheuner Corp., 841 F.2d 151, 154 (6th Cir. 1988)); Therma-Scan, Inc. v. Thermoscan, Inc., 217 F.3d 414, 419 (6th Cir. 2000) (“This circuit has long recognized the broad, inherent authority and equitable power of a district court to enforce an agreement in settlement of litigation pending before it....” (quoting Bostick Foundry Co. v. Lindberg, 797 F.2d 280, 282-83 (6th Cir. 1986)). This inherent power stems “from the policy favoring the settlement of disputes and the avoidance of costly and time-consuming litigation.” Henley v. Cuyahoga Cnty. Bd. of Mental Retardation & Developmental Disabilities, 141 Fed.Appx. 437, 443 (6th Cir. 2005).

         “[O]nce a settlement is reached, it is the party challenging the settlement who bears the burden to show that the settlement contract was invalid based on fraud or mutual mistake.” Id.

         Before a district court enforces a settlement, it “must conclude that agreement has been reached on all material terms.” RE/MAX Int'l, Inc. v. Realty One, Inc., 271 F.3d 633, 645-46 (6th Cir. 2001). “[A] settlement agreement is as binding, conclusive, and final as if it had been incorporated into a judgment.” Id. at 650 (citing Clinton St. Greater Bethlehem Church v. City of Detroit, 484 F.2d 185, 189 (6th Cir. 1973)). Such a judgment “is in the nature of a judgment by consent.” Kukla v. Nat'l Distillers Prod. Co., 483 F.2d 619, 621 (6th Cir. 1973).

         The Court looks to state law of contracts to resolve disputes as to the enforcement of settlement agreements. Cuyahoga Valley Ry. Co. v. U.S. Bank Tr. Nat'l Ass'n, 515 Fed.Appx. 494, 498 (6th Cir. 2013) (“Because settlement agreements are a type of contract, the formation and enforceability of a purported settlement agreement are governed by state contract law.” (quoting Smith v. ABN AMRO Mortg. Grp. Inc., 434 Fed.Appx. 454, 460 (6th Cir. 2011)); see also Envtl. Abatement, Inc. v. Astrum R.E. Corp., 27 S.W.3d 530, 539 (Tenn. Ct. App. 2000) (observing that “[a] compromise and settlement agreement is merely a contract between the parties to litigation and, as such, issues of enforceability of a settlement agreement are governed by contract law”).

         B. State Law (Contracts)

         As noted, Plaintiff's attack on the settlement agreement is four-pronged (i.e., no meeting of the minds, mutual ...


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