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LNV Corp. v. Studle

Emails exchanged between the parties constituted a valid settlement offer and acceptance thereof.

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LNV Corporation “LNV” sued Charles and Daniel Studle to recover amounts owed on two commercial promissory notes. After the parties engaged in settlement discussions, the Studles filed a motion to enforce a settlement agreement between the parties. The trial court granted the Studles’ motion, finding that emails exchanged between the parties constituted a valid settlement offer and acceptance thereof. LNV appeals, contending that the trial court erred in 1 not admitting parol evidence concerning ambiguities in the purported offer and acceptance, and 2 granting the Studles’ motion to enforce the settlement agreement. For the reasons that follow, we affirm.

We apply a de novo standard of review to a trial court’s order on a motion to enforce a settlement agreement. Because the issues raised are analogous to those in a motion for summary judgment, in order to succeed on a motion to enforce a settlement agreement, a party must show the Court that the documents, affidavits, depositions and other evidence in the record reveal that there is no evidence sufficient to create a jury issue on at least one essential element of the Appellant’s case. Thus, we view the evidence in a light most favorable to the nonmoving party.

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