Unreported / Non-Citable
Background
Plaintiff Leah Sophia Arredondo filed a negligence and premises liability action in California Superior Court on July 11, 2024, alleging she slipped and fell at a Costco warehouse in Chula Vista on July 30, 2022. Costco removed the case to federal court on February 7, 2025. The parties participated in an Early Neutral Evaluation before Magistrate Judge Michelle M. Pettit on May 1, 2025, and a Mandatory Settlement Conference (MSC) on November 12, 2025. At the MSC, with Plaintiff, her counsel, an interpreter, and Costco’s representative present, the parties settled all claims.
Judge Pettit recited the terms on the record: Costco would pay $25,000; Plaintiff would waive all claims; the agreement included confidentiality and non-disparagement clauses; Plaintiff would provide a CMS form for Medicare/Medi-Cal issues; the parties would execute a long-form release; and each side would bear its own fees and costs. Plaintiff’s counsel confirmed no terms were missing, and Plaintiff personally affirmed twice through the interpreter that she understood and agreed to be bound. Costco’s representative also agreed. Costco subsequently sent settlement documents, but Plaintiff refused to sign. After multiple settlement disposition conferences where Plaintiff stated she did not intend to sign, Costco filed the motion to enforce.
The Court’s Holding
The Court granted Costco’s motion to enforce the settlement agreement. The Court found the oral agreement reached on the record at the MSC was complete and binding, encompassing all material terms. Plaintiff’s objective assent was established by her unambiguous affirmative responses to the court’s questions, made through a qualified interpreter who had assisted her throughout the proceedings.
The Court rejected Plaintiff’s arguments that her assent was not knowing or voluntary because she allegedly misunderstood her medical liens or the net recovery amount, holding that a party’s unilateral mistake about her own financial obligations or the future conduct of third-party lienholders does not invalidate a settlement. The anticipated long-form release did not render the agreement incomplete, as the parties did not condition binding effect on its execution. The Court further held that no evidentiary hearing was required because Plaintiff submitted no competent evidence—only argument—to create a genuine dispute of material fact regarding the agreement’s existence, terms, or her assent. The Court ordered the parties to comply with the settlement terms by October 30, 2026, and file a joint motion to dismiss with prejudice by November 16, 2026.
Key Takeaways
- An oral settlement agreement recited on the record in open court is binding even if a party later refuses to sign written documents conforming to those terms.
- A party’s subjective misunderstanding of her own medical liens or net recovery, without evidence of fraud or mutual mistake, does not invalidate a settlement where the party affirmed understanding and assent on the record.
- The requirement of a future long-form release does not prevent enforcement of an otherwise complete oral agreement unless execution is expressly made a condition precedent.
- A non-English-speaking plaintiff’s assent through a court-approved interpreter, confirmed by direct colloquy with the court, constitutes objective mutual assent.
- To oppose a motion to enforce settlement, a party must present competent evidence (e.g., a declaration) creating a genuine factual dispute; argument in a brief is insufficient.
Why It Matters
This decision reinforces the strong judicial policy favoring enforcement of settlements reached during court-supervised conferences.
It clarifies that a plaintiff’s post-hoc dissatisfaction with the economic outcome of a settlement—particularly regarding unanticipated medical lien amounts—does not constitute grounds for rescission based on unilateral mistake when the plaintiff was represented by counsel, had interpreter assistance, and personally affirmed the terms on the record. The ruling also underscores the evidentiary burden on a party seeking to avoid a settlement: mere allegations in an opposition brief, without supporting declarations or admissible evidence, cannot defeat summary enforcement.