Doe v. Lozano
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The Supreme Court vacated the judgment of the district court determining that a settlement agreement signed by the parties constituted a binding contract and granting Plaintiff's motion to enforce the agreement, holding that issues of fact regarding the formation of the settlement agreement existed.
Plaintiff bought this complaint against Defendant for unjust enrichment and partition of real estate. Plaintiff filed with the court a settlement agreement, signed by both parties, stating that the parties were previously in a personal and business relationship and seeking to resolve all issues arising from that relationship. Plaintiff then filed a motion to enforce that agreement and a declaration that the agreement was valid. The court approved the settlement agreement and entered judgment for Plaintiff. The Supreme Court reversed, holding (1) if a party raises a factual issue that goes to the validity of a settlement agreement’s formation, an evidentiary hearing will generally be necessary on a motion to enforce the settlement, even if the written agreement otherwise appears to be a fully integrated contract; and (2) because no such hearing was held in this case the judgment must be vacated.
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