Affirming a district court's motion to enforce a mediated settlement of a medical malpractice dispute, a Minnesota appellate court held that the party seeking to vacate the settlement agreement failed to prove that he was intoxicated or incompetent when he entered into the agreement.

In Soderbeck v. Center for Diagnostic Imaging, Inc., No. A06-2369, 2007 WL 4564109 (Minn. Ct. App. Dec. 31, 2007), a piece of steel became lodged in Soderbeck's right eye after an accident in 1980. In March 2001, Soderbeck went to the Center Diagnostic Imaging (CDI) for an MRI after suffering a separate shoulder injury. Soderbeck allegedly told CDI that he had a metal fragment in his eye. During the MRI scan, Soderbeck felt pain in his eye and became very nauseous. In May 2001, doctors surgically removed Soderbeck's right eye, but he continued to suffer severe symptoms.

In 2003, Soderbeck sued CDI for personal injury. Afterward, Soderbeck and CDI agreed to mediate their dispute. The parties reached a settlement agreement whereby CDI agreed to pay Soderbeck $150,000. The next day, Soderbeck told his lawyer he was refusing the settlement agreement.

CDI brought a motion to enforce the settlement agreement. Soderbeck opposed the motion, arguing he was incompetent because he was under the influence of Neurontin, a pain medication. The district court granted CDI's motion, finding Soderbeck failed to demonstrate he was incompetent at the time of the mediation.

On appeal, the Court held that Soderbeck had sufficient mental capacity to understand what he was doing when he entered into the settlement agreement. Under Minnesota law, "the party seeking to avoid a settlement has the burden of showing sufficient grounds for its vacation." The Court concluded that Soderbeck failed to meet that burden.

Specifically, the Court relied on testimony from Soderbeck's attorney and the mediator indicating that Soderbeck did not appear intoxicated. Moreover, Soderbeck's own witness only testified that Soderbeck took medication, not that he appeared intoxicated at the mediation. Finally, Soderbeck declined the district court's offer to hold an additional evidentiary hearing allowing him to produce medical evidence attesting to his impairment.