Bandera v. City of Quincy

344 F.3d 47 (1st Cir. 2003)



A trial court may not summarily enforce a settlement agreement if material facts are in dispute as to the validity or terms of the agreement. But by the same token the district court cannot summarily deny enforcement simply because material facts are in dispute: the task is to resolve the dispute.


The employee was hired by the employer and alleged that she was excluded from meetings, ridiculed, and subjected by male officers to graphic details of their sexual exploits. She filed a sexual harassment claim pursuant to 42 U.S.C.S. § 2000e42 U.S.C.S. § 1983, and the Massachusetts Fair Employment Practices Act, Mass. Gen. Laws ch. 151B (2000). The jury awarded her $ 135,000 in punitive damages and the employer appealed, alleging that the claim was barred by a prior purported settlement agreement and that the trial was infected by error. The employee claims, however, that she was improperly coerced into signing the agreement.


Should the judgment in favor of the employee be set aside in light of the alleged settlement agreement entered into by the parties?


Yes, provided the settlement agreement is valid.


The court ruled that the judgment must be set aside by the district court if in further proceedings it was determined that a valid settlement agreement was established requiring a release of the employee's claims; however, if the settlement agreement proved in further proceedings not to have been a bar, then the judgment stood. Thus, the court concluded that the judgment of the district court was stayed pending further order of the district court.

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