United States District Court, D. Idaho
MEMORANDUM DECISION AND ORDER
EDWARD J. LODGE, District Judge.
Currently pending before the Court is Defendant's Motion to Enforce Settlement Agreement ("Motion to Enforce") (Dkt. 16). In the interest of avoiding further delay and because the Court conclusively finds that the decisional process would not be significantly aided by oral argument, the Court will address and resolve this motion without a hearing. Therefore, having carefully reviewed the record, the Court enters the following Order.
On August 8, 2012, Plaintiff Kimberly Kaiser ("Kaiser" or "Plaintiff") filed a Complaint in Idaho state court alleging violation of the Idaho Human Rights Act, I.C. § 67-5901 et. seq., against Defendant TRACE, Inc. ("Defendant" or "TRACE"). (Dkt. 1.) After Kaiser filed an Amended Complaint in December, 2012, Defendant removed the case to federal court pursuant to Title VII of the Civil Rights Act, as amended by the Pregnancy Discrimination Act of 1978, 42 U.S.C. § 2000e, because Kaiser's claims gave rise to a dispute related to workplace discrimination and retaliation and involved a federal question. ( Id., ¶ 3.)
The parties eventually participated in mediation with mediator James D. Huegli ("Huegli") on October 21, 2013. (Dkt. 16-1, p. 1.) In support of its Motion to Enforce, Defendant submitted an affidavit from Huegli stating the parties were successful in reaching a settlement agreement through mediation. (Dkt. 16-2, p. 1.) Following the mediation, Huegli sent an email to counsel for the parties summarizing the parties' settlement agreement. Huegli's October 21, 2013 email memorialized the following settlement terms:
1. The plaintiff will dismiss the case with prejudice and without costs;
2. The defendant will pay the entire mediation fee and pay for Plaintiff's out of pocket costs... [of] about $1600. Plaintiff will submit either a summary of those costs or a letter from counsel that the amount represents the costs expended.
3. Defendant will prepare a standard release between the parties.
( Id., p. 4.)
The Court was also notified on October 22, 2013 that the case had been settled in its entirety in mediation and that a stipulation of dismissal would be forthcoming. (Dkt. 12.)
Defendant thereafter paid the entire mediation fee and prepared and delivered a Settlement Agreement and Release of All Claims ("Settlement and Release") to Kaiser's counsel for Kaiser's signature. (Dkt. 16-1, p. 2.) Defendant also drafted a check payable to Kaiser's counsel for approximately $1600 of out of pocket expenses, but held the check awaiting Kaiser's signature upon the Settlement and Release and stipulation to dismiss the case with prejudice. (Dkt. 16-3, p. 2, ¶ 4.) Kaiser's counsel subsequently informed Defendant that Kaiser had decided not to continue with settlement discussions, and would proceed with prosecuting her case. (Dkt. 16-3, p. 10.) On December 13, 2013 the Court was notified that the terms of the settlement agreement were not fulfilled. (Dkt. 13.) Defendant thereafter filed the instant motion, claiming Kaiser's refusal to perform constitutes a breach of the settlement agreement and asking this Court to order Kaiser to perform under the agreement.
Defendant claims that the parties entered into an enforceable settlement contract on October 21, 2013 when the parties orally agreed to a settlement during mediation. Kaiser denies that the oral agreement comprised all of the material terms of the settlement, and suggests the parties intended to formalize the agreement in writing. Generally, oral agreements do not have to be reduced to writing to be enforceable. McColm-Traska v. Baker, 88 P.3d 767, 770 (Idaho 2004) (citing Lyle v. Koubourlis , 771 P.2d 907, 909 (Idaho 1988). However, oral settlement agreements must comply with the general requirements for contracts. Id. Thus, for an oral settlement agreement to be enforceable, there must be manifestation of mutual intent to contract, as well as a meeting of the minds regarding the essential terms of the agreement. Lawrence v. Hutchinson, 204 P.3d 532, 538 (Idaho App. 2009). To be enforceable, a "contract must be complete, definite, and certain in all its material terms, or contain provisions which are capable in themselves of being reduced to certainty." Id. (citations omitted).
Where, as here, the parties enter into an oral agreement but contemplate a formal writing, the question of whether the parties become bound prior to the drafting and execution of the formal writing, "is largely a question of intent." Kohring v. Robertson, 44 P.3d ...