Law School Case Brief
Trs. of the Am. Fed'n of Musicians & Employers' Pension Fund v. Steven Scott Enters., Inc. - 40 F. Supp. 2d 503 (S.D.N.Y. 1999)
Fed. R. Civ. P. 56(c) states that summary judgment shall be granted if there is no genuine issue as to any material fact and the moving party is entitled to a judgment as a matter of law. A dispute about a material fact is genuine if the evidence is such that a reasonable jury could return a verdict for the non-moving party.
Seeking to audit defendant's payroll records, plaintiff trustees brought suit under the Employee Retirement Income Security Act. Defendant filed a motion for summary judgment, arguing that plaintiffs should be estopped from denying that they were bound by the settlement agreements because he relied on plaintiffs' agent's representations that he was authorized to bind plaintiffs.
Were the plaintiff trustees estopped from denying that they were bound by their ratified settlement agreements?
The court found that extraordinary circumstances existed thus establishing all four elements of equitable estoppel. The court held that plaintiffs were estopped from denying that they were bound by the settlement agreements. Also, because of plaintiffs' silence, the court found that a reasonable fact-finder would conclude that the agent was acting with apparent authority when he negotiated the settlement agreements.
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