Western Thrift and Loan Corp. v. Rucci, No. 14-3150 (8th Cir. 2016)
Annotate this CaseDefendant appealed the district court's order enforcing the terms of an agreement he entered into with Western Thrift and Loan Corporation to settle a malpractice lawsuit. The court concluded that a district court may retain ancillary jurisdiction to enforce a settlement agreement when its order dismissing the case reserves such jurisdiction. Here, the district court's dismissal order expressly reserved ancillary jurisdiction to enforce the terms of the settlement agreement for forty-five days. The district court therefore had jurisdiction to enforce the agreement, because Western Thrift moved to enforce the settlement agreement within the forty-five day time period. The court also concluded that the record itself was sufficient to create a enforceable settlement agreement, even though the parties did not memorialize the agreement. Accordingly, the court affirmed the judgment.
Court Description: Bye, Author, with Smith and Benton, Circuit Judges] Civil case - Settlements. District court retained ancillary jurisdiction to enforce a settlement agreement when its order dismissing the case reserved such jurisdiction; the district court record was sufficient to create an enforceable agreement even though the parties did not memorialize the agreement.
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