Conway v. Healthfirst Inc.

Background

Patrick Conway filed this action against Healthfirst Inc. He asserted claims under the Americans with Disabilities Act, the Rehabilitation Act, and the New York City Human Rights Law. The court had previously granted Healthfirst’s motion to dismiss the third amended complaint as to all claims except Conway’s retaliation claims under the Americans with Disabilities Act and the Rehabilitation Act.

The parties later attended a settlement conference before Magistrate Judge Netburn. They agreed on material settlement terms and agreed to create a binding oral contract. After Healthfirst prepared a written version, Conway changed his mind and refused to sign it. Healthfirst then moved to enforce the settlement terms. Conway did not oppose that motion.

Report and recommendation

Magistrate Judge Netburn recommended granting Healthfirst’s motion to enforce the settlement and dismissing Conway’s complaint with prejudice. Neither party objected to the recommendation.

Because there were no objections, Judge Abrams reviewed the recommendation for clear error, meaning an obvious mistake in the record. The court found no error and adopted the recommendation in its entirety.

Ruling

The court held that the parties were bound by the settlement agreement, granted Healthfirst’s motion to enforce the settlement, and dismissed Conway’s complaint with prejudice. The clerk was directed to enter judgment for Healthfirst and close the case.