The 1st U.S. Circuit Court of Appeals has denied a plaintiff’s request to back out of her agreement to settle her Fair Labor Standards Act claims against her former employer.
On March 6, 2024, the parties and counsel participated in a court-annexed settlement conference before a magistrate judge, with the plaintiff appearing by Zoom, and reached an oral settlement agreement. After the judge recited the essential terms of the agreement on the record, counsel for both parties orally agreed on the record with the recitation.
On July 16, 2024, defendant Siemens filed a motion to enforce the settlement agreement. That motion was allowed by U.S. District Court Judge John J. McConnell Jr., who later denied a motion by the plaintiff for reconsideration under Rule 60(b)(1) of the Federal Rules of Civil Procedure.
“On appeal, [the plaintiff] argues that the district judge erred in determining that she entered into a binding settlement agreement at the time of the settlement conference. That argument is meritless,” Judge Gustavo A. Gelpí wrote for the three-judge 1st Circuit panel.
“At the March 6, 2024 settlement conference, the parties actively engaged in negotiations before the magistrate judge and ultimately agreed on the material terms recited on the record. When the magistrate judge carefully recited and memorialized those terms, [the plaintiff] did not object or condition her assent, nor did her counsel. To the contrary, her counsel expressly confirmed her agreement, and [the...
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