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Keywords

contractsettlementbreach of contractmediationstatuteappealdiscriminationregulation
settlementappealmotionsummary judgmentregulationmotion to dismissmotion for summary judgment

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Bullock v. United States, 10 F.4th 1317

Facts

Ellen P. Bullock, a civilian employee of the Army, filed an EEO claim alleging sex discrimination and retaliation after receiving a formal reprimand. Following an investigation, Bullock sought to settle her claims through mediation, where she and the Army representatives allegedly reached an oral agreement on both monetary and nonmonetary demands. However, the Army later rescinded its settlement offer, leading Bullock to file a breach of contract claim in the Claims Court after the mediation failed.

Ms. Bullock is a civilian employed by the Army at Joint Base Langley-Eustis in southern Virginia as part of the U.S. Army Aviation and Missile Command, Aviation Integration Directorate.

Issue

Whether EEOC and Army regulations requiring settlement agreements to be in writing preclude the enforcement of oral settlement agreements.

Whether the EEOC regulations and the Army's EEO regulations preclude enforcement of a purported oral agreement.

Rule

The court held that oral agreements to settle EEO claims are enforceable and that the regulations in question do not invalidate such agreements.

We think that the Claims Court erred in finding that there was a forfeiture because the issue had been briefed in connection with the motion to dismiss and the Claims Court converted the motion to dismiss into a motion for summary judgment.

Analysis

The court analyzed the EEOC and Army regulations and concluded that they are housekeeping provisions that do not render oral agreements unenforceable. The court emphasized that there is no federal statute requiring written agreements in this context and that the regulations do not specify consequences for failing to comply with the writing requirement.

The court concluded that the two regulations cannot be interpreted as directed to enforceability.

Conclusion

The Court of Appeals reversed the Claims Court's decision and remanded the case for further proceedings to determine whether the Army representative had the authority to enter into the settlement agreement and whether an agreement was actually reached.

Having concluded that the Claims Court erroneously held that oral settlement agreements are unenforceable, we reverse and remand to the Claims Court to decide the two factual issues it did not address in its summary judgment order.

Who won?

Ellen P. Bullock prevailed in the appeal because the court found that the Claims Court erred in its interpretation of the regulations regarding oral agreements.

Ellen P. Bullock prevailed in the appeal because the court found that the Claims Court erred in its interpretation of the regulations regarding oral agreements.

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