Ex parte Ford - 782 So. 2d 185 (Ala. 2000)

Rule:

Ala. Code 25-5-292(b) (1975) provides that a settlement agreement entered into at a benefit-review conference is binding on all parties through the final conclusion of all matters relating to the claim, unless within 60 days after the agreement is signed or approved the court on a finding of fraud, newly discovered evidence, or other good cause, shall relieve all parties of the effect of the agreement.

Facts:

Plaintiff Margaret Ford was employed by Cagles, Inc. Plaintiff alleged that she had suffered work-related injuries. Plaintiff sued Cagles, seeking workers’ compensation benefits. Plaintiff and Cagles agreed to participate in a benefit review conference, pursuant to Ala. Code 1975, §§ 25-5-290 through -292. At the benefit-review conference, plaintiff settled her workers’ compensation claim against Cagles. The settlement agreement was reduced to writing and was signed by both parties. Plaintiff later changed her mind about the agreement. Cagles then filed a motion to enforce the agreement. Plaintiff objected to the motion to enforce the agreement and asked the court to set aside the agreement. The trial court granted Cagles's motion to enforce the agreement. The Court of Civil Appeals affirmed. On certiorari review, plaintiff argued that the trial court erred in approving and enforcing the settlement agreement without first finding either that the agreement was in her best interest or that the agreement would pay her at least as much as she would have been entitled to under the Workers' Compensation Act.

Issue:

Did the trial court err in approving and enforcing the settlement agreement? 

Answer:

No.

Conclusion:

The court affirmed the order of the court of appeals, and disagreed with the plaintiff’s contention. According to the court, approval of the settlement agreement was not required, and plaintiff did not seek court review of the agreement within 60 days after the parties had signed it. Because plaintiff's request to set the agreement aside was made more than 60 days after the parties had signed the agreement, the trial court did not have jurisdiction to set it aside. Therefore, the trial court properly refused to do so.