Summary
The Rhode Island Supreme Court affirmed the denial of Nicole Rivera's motion to vacate a settlement and dismissal stipulation under Rule 60(b). The court held that Rivera failed to prove mutual mistake by clear and convincing evidence because the releases and indemnification agreement unambiguously provided for a complete settlement and did not include the alleged agreement concerning medical-bill subrogation. The court also concluded that additional testimony was unnecessary and would constitute inadmissible parol evidence.
Topics
Practice areas
Questions Presented
- Whether Rule 60(b) could provide relief from the settlement agreement and dismissal stipulation.
- Whether Rivera proved by clear and convincing evidence that the settlement documents resulted from a mutual mistake.
- Whether the settlement documents were ambiguous or could be modified through extrinsic evidence concerning an alleged agreement about payment of medical bills.
- Whether the Superior Court abused its discretion by denying Rivera an additional evidentiary hearing.
Holdings
- A party seeking to vacate a settlement release and dismissal stipulation on the ground of mutual mistake must prove the mutual mistake by clear and convincing evidence. Rivera failed to meet that burden because the alleged agreement concerning medical bills was not reflected in any of the written settlement documents.
- The three settlement documents were clear and unambiguous, and their plain terms controlled. Extrinsic evidence of an alleged verbal agreement concerning the medical lien was inadmissible to modify the written releases and indemnification agreement.
- The Superior Court did not abuse its discretion by declining to continue the matter or conduct an additional evidentiary hearing because the parties had already argued their positions, submitted memoranda, and provided affidavits that adequately presented the issue.
- A party who signs an instrument manifests assent to it and cannot later avoid its terms merely by asserting that the party did not read or understand the instrument's contents.
Key quotations
“Mutual mistake is defined as a mistake "common to both parties wherein each labors under a misconception respecting the same terms of the written agreement sought to be canceled."” (284)
“We conclude that in this instance, plaintiff made a unilateral mistake by not memorializing the terms of the agreement as she understood them.” (285)
“"It is a basic tenet of contract law that the contracting parties can make as `good a deal or as bad a deal' as they see fit * * *."” (285)
Factual background
On September 21, 2001, Nicole Rivera was injured while riding in a vehicle that was struck from behind by a vehicle driven by Danielle Gagnon. Rivera's counsel negotiated a $3,000 settlement with Gagnon's insurer, and Rivera's mother signed three documents releasing claims and agreeing to indemnify the defendants. After the insurer refused to issue the settlement check without listing Concord, which had asserted a lien for medical payments, Rivera argued that the settlement was based on a mutual understanding that medical bills would be handled through subrogation and sought to vacate the dismissal stipulation.
Procedural history
Nicole Rivera, through her mother and natural guardian, settled her personal-injury claim for $3,000 and entered releases and indemnification agreements. After the settlement insurer included Concord as a payee because of Concord's medical-payment lien, Rivera sought to vacate the dismissal stipulation and settlement under Rule 60(b), alleging mutual mistake. The Superior Court denied the motion, and the Supreme Court of Rhode Island affirmed and remanded the record.
Remand instructions
The record was remanded to the Superior Court following affirmance of its judgment.