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Keywords

contractlawsuitsettlementlitigationequityappealtrialleaseseizure

contractsettlementlitigationappealtrialseizure

Related Cases

Poly Trucking, Inc. v. Concentra Health Services, Inc., 93 P.3d 561

Facts

The case arose from a motor vehicle accident caused by a commercial truck driver employed by Poly Trucking, who had a seizure and lost consciousness, leading to a collision that resulted in a fatality. The widow of the deceased filed a wrongful death lawsuit against Poly and the truck driver, while Poly brought third-party claims against Concentra Health Services for allegedly improperly issuing a medical certification to the driver. During settlement negotiations, a settlement agreement was reached, but the doctors employed by Concentra were not included in the release. After the settlement, Concentra sought to reform the agreement to include its doctors, leading to the appeal by Poly.

Issue

Did Poly Trucking have a duty to disclose its intent to reserve the right to sue the doctors employed by Concentra during the settlement negotiations?

Rule

Reformation of a contract is permitted when there is a mutual mistake or a unilateral mistake accompanied by fraud or inequitable conduct. A party has a duty to disclose material facts that should be disclosed in equity and good conscience.

Reformation of a contract is permitted when there is a mutual mistake or a unilateral mistake accompanied by fraud or inequitable conduct.

Analysis

The court found that while Concentra made a unilateral mistake in drafting the settlement agreement, Poly did not engage in any fraudulent conduct or have a duty to disclose its litigation strategy. The court emphasized that the parties were in an adversarial relationship and that mere silence does not constitute fraud. The absence of any discussion regarding the doctors during negotiations indicated that Poly's intent to reserve the right to sue was not a material fact that needed to be disclosed.

The court found that while Concentra made a unilateral mistake in drafting the settlement agreement, Poly did not engage in any fraudulent conduct or have a duty to disclose its litigation strategy.

Conclusion

The Court of Appeals reversed the trial court's order reforming the settlement agreement, concluding that Poly had no duty to disclose its intent to reserve the right to sue the doctors.

Who won?

Poly Trucking prevailed in the case because the court found that it had no duty to disclose its litigation strategy during settlement negotiations.

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