United States District Court, E.D. Tennessee
MEMORANDUM OPINION AND ORDER
RONNIE GREER UNITED STATES DISTRICT JUDGE
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
AND PROCEDURAL BACKGROUND
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].
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]. Plaintiff
responded in objection to the motion and asked the Court to
set aside the settlement agreement [Doc. 88, sealed].
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.
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,
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.
LAW AND ANALYSIS
Enforcement of Settlement Agreements
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).
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.”
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).
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”).
State Law (Contracts)
noted, Plaintiff's attack on the settlement agreement is
four-pronged (i.e., no meeting of the minds, mutual ...