BANYAN POINT CONDOMINIUM ASSOCIATION, INC.
v.
INDIAN HARBOR INSURANCE COMPANY
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The District Court denied Defendant Indian Harbor Insurance Company's Motion to Enforce Settlement in a dismissed breach of contract action. The court held that while federal courts have inherent power to enforce settlement agreements in pending cases, they lack jurisdiction to enforce settlements in non-pending cases unless jurisdiction was specifically retained.
Federal courts lack jurisdiction to enforce settlement agreements in non-pending cases absent specific retention of jurisdiction. Because this case was dismissed with prejudice and is no longer pending, and the court did not retain jurisdiction, the motion to enforce the settlement must be denied.
[1] Federal courts possess inherent power to summarily enforce settlement agreements entered into by parties in a pending case.
[2] A federal court lacks jurisdiction to enforce a settlement agreement in a non-pending case unless jurisdiction was specifically retained.
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Join FLexlaw to unlock all legal intelligence“Federal courts possess the "inherent power to summarily enforce settlement agreements entered into by parties litigant in a pending case."”
Establishes the general rule that courts can enforce settlements, but only in pending cases.
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Join FLexlaw to unlock all legal intelligenceBanyan Point Condominium Association filed a breach of contract action against Indian Harbor Insurance Company, which was removed to federal court in …
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Before the Court is Defendant Indian Harbor Insurance Company's Motion to Enforce Settlement. (Doc. 23). Though the deadline to respond has passed under Local Rule 3.01(c), Plaintiff Banyan Point Condominium Association, Inc. has not responded.
This case was a breach of contract action removed to this Court in March 2024. (Doc. 1). The parties settled the case in May 2024. (Doc. 19). The Court dismissed the action without prejudice based on the Notice of Settlement. (Doc. 21). The Court warned that this dismissal would ripen into prejudice on June 20, 2024, if neither party filed another paper per Local Rule 3.09(b). (Doc. 21). Neither party filed another paper until Indian Harbor filed its Motion to Enforce Settlement in August 2024. (Doc. 23).
Federal courts possess the “inherent power to summarily enforce settlement agreements entered into by parties litigant in a pending case.” Ford v. Citizens & Southern Nat'l Bank, 928 F. 2d 1118, 1121 (11th Cir. 1991) (internal citation omitted) (emphasis added). But in a non-pending case, the Court does not have jurisdiction over a settlement agreement unless the Court specifically retained jurisdiction. See Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 378, 114 S. Ct. 1673, 128 L. Ed. 2d 391 (1994); Ат. Disability Ass’n, Inc. v. Chmielarz, 289 F. 3d 1315, 1320-1321 (11th Cir. 2002).
This case has been dismissed with prejudice. As such, it is no longer "pending." And the Court did not retain jurisdiction to enforce the settlement agreement. Accordingly, Indian Harbor's Motion to Enforce Settlement is denied.
Accordingly, it is now ORDERED:
Defendant Indian Harbor Insurance Company's Motion to Enforce Settlement (Doc. 23) is DENIED. This action remains dismissed, and the case remains closed.
DONE and ORDERED in Fort Myers, Florida on September 10, 2024.
Sheri Polster Rappell
SHERI POLSTER CHAPPELL
UNITED STATES DISTRICT JUDGE
Copies: All Parties of Record
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