Background
Jelani Manzili, administrator of the estate of his mother, Grace Ann Brown, sued the operators of her nursing home, alleging negligent care before her death. The parties mediated the case and continued negotiating after the initial mediation session did not produce an agreement.
Defendants first offered the remaining $243,927.20 of their policy limits. Manzili’s attorney responded that he had authority to accept $300,000. Defendants then agreed to pay $300,000, and the mediator confirmed the settlement by email. When Manzili declined to sign the settlement agreement and release, defendants moved to enforce the settlement. The circuit court granted that motion.
The Court’s Holding
The Illinois Appellate Court affirmed. Applying contract principles and reviewing de novo because the enforcement ruling rested on the motion, pleadings, and attachments without an evidentiary hearing, the court held that the record showed a binding $300,000 settlement.
Manzili argued that he had withdrawn his attorney’s authority during mediation through a text exchange rejecting a $200,000 offer. The appellate court refused to consider that exchange because nothing showed it had been presented to the trial court; a supplemental appellate record may include only materials that were before the trial court. The record instead showed that counsel had authority to settle for $300,000, with no evidence that Manzili withheld or revoked that authority. The parties therefore had a meeting of the minds.
Key Takeaways
- An oral settlement may be enforceable when offer, acceptance, and agreement on material terms are shown.
- An appellate court cannot rely on material added to the record that was not before the trial court.
- A party challenging a settlement must point to record evidence that settlement authority was withheld or revoked.
Why It Matters
The decision underscores that settlement authority communicated by counsel can bind a client when the record objectively establishes agreement on the settlement terms. A later refusal to execute customary settlement documents does not defeat an already formed agreement.
It also highlights the importance of creating a trial-court record. Evidence supporting a claimed revocation of counsel’s authority must be presented below; it cannot be introduced for the first time on appeal through record supplementation.