Commonwealth School, Inc. v. Commonwealth Academy Holdings LLC, No. 20-1112 (1st Cir. 2021)Annotate this Case
The First Circuit reversed the order of the district court dismissing this appeal, holding that the district court erred both in refusing to enforce the contested agreement and in dismissing the case after effectively declaring the agreement null and void.
The Commonwealth School, Inc. brought suit against Commonwealth Academy Holdings, LLC under the Lanham Act, 15 U.S.C. 1114(A) and 1125(a), alleging that the School had trademarked the name "Commonwealth School" and that the Academy's name, "Commonwealth Academy," infringed that trademark. The parties achieved a settlement agreement, and the district court conditionally dismissed the case. When the parties failed to memorialize the agreement the School moved to reopen the case. The Academy, in response, moved for enforcement of the settlement agreement. The district court refused to enforce the settlement, finding that there had not been a meeting of the minds, and then dismissed the case. The First Circuit reversed, holding (1) this Court had jurisdiction to hear and determine this appeal; (2) enforcement of the settlement agreement was within the district court's jurisdictional orbit; and (3) the settlement agreement was valid and enforceable, and therefore, the district court erred in refusing to enforce the agreement and in dismissing the case.