Edwin Ricardo v. Typtap Insurance Company

Summary

The Third District Court of Appeal of Florida reversed an order enforcing an alleged mediated settlement agreement between the Ricardos and Typtap Insurance Company. The court held that disputed issues concerning contract formation and mutual assent required further proceedings, including an evidentiary hearing where necessary, and vacated the related sanctions award.

Holdings

1. When the existence or formation of a settlement agreement depends on disputed material facts, the trial court must conduct further proceedings, including an evidentiary hearing where necessary, before enforcing the agreement.
2. The sanctions order must be vacated because reversal of the order enforcing the settlement requires further proceedings concerning the settlement's validity.

Questions Presented

1. Whether the trial court could enforce the purported mediated settlement agreement without conducting an evidentiary hearing when the parties disputed material facts concerning essential terms, mutual assent, and acceptance before revocation.
2. Whether the sanctions order could stand after reversal of the order enforcing the settlement agreement.

Disposition

reversed_and_remanded