The Second Appellate District reversed a judgment. The court held that an obligor’s statement that a payment was under “under protest” was not enough to render the payment involuntary.

Mark Steinman and the Steinman Family Trust settled an action against Kenneth Malamed and Financial Management Advisors, Inc. and LLC. The trial court dismissed the action pursuant to a stipulation by the parties and retained jurisdiction to enforce the settlement agreement. The agreement included a provision for a prepayment discount.