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The Idaho Supreme Court upheld a lower court decision enforcing a settlement agreement, noting that courts ruling on the enforceability of a settlement agreement should not inquire into the merits of the underlying claim.
In Goodman v. Lothrop, Nos. 31291, 31292, 2007 WL 14560 (Idaho Jan. 4, 2007), Lothrop obtained property from her mother, Hess, via a warranty deed.
Subsequently, Lothrop and Hess were involved in a property boundary dispute with a neighbor, Goodman. The trial court ordered the parties to participate in mediation. At mediation, which Hess did not attend, Lothrop and Goodman agreed to a settlement.
Following mediation, Lothrop and Hess repudiated the agreement, prompting Goodman to file a motion to enforce the settlement agreement.
Lothrop and Hess "strenuously" argued the underlying merits of the dispute. However, the Court rejected these arguments and enforced the settlement agreement, citing the rule that courts "will not inquire into the merits or validity of the original claim" in actions to enforce a settlement agreement.
Additionally, Lothrop argued that the mediation agreement should not be enforced because "the mediator was intimidating and exerted 'undue influence' on [her]." The Court rejected Lothrop's claim of duress because there were no "specific factual allegations from which a court could infer that the mediator engaged in wrongful conduct that overcame Lothrop's ability to exercise her free will."
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