Alicea v. Remulla

Background

Eddie Alicea brought this action concerning federal police officers’ conduct during an interaction at a Veterans Hospital. According to the complaint, Alicea’s refusal to use hand sanitizer because of a skin condition led to officers placing him in a chokehold, throwing him to the ground, handcuffing him, and putting him in a holding cell. The court had previously dismissed all claims except claims against the United States under the Federal Tort Claims Act.

On January 15, 2025, the parties participated in a settlement conference before Judge Kandis A. Westmore. The parties orally agreed that the United States would pay $100,000 in exchange for Alicea’s release of his claims. The next day, defense counsel sent an email confirming the settlement, and Alicea’s then-lawyers confirmed it. The parties later circulated a draft written agreement and filed a notice stating that they had reached a conditional settlement of all claims.

Alicea’s lawyers later reported that the parties had agreed in principle but that Alicea had not signed the written agreement. Alicea also told the court that he intended to terminate his lawyers and later said he wanted to rescind the settlement. The court allowed his lawyers to withdraw. The United States moved to enforce the settlement. Alicea did not initially file an opposition, but after the court gave him another opportunity because he was representing himself, he filed an untimely opposition that the court accepted.

Legal standard

The court explained that a federal district court may enforce a settlement agreement in a case before it. The party seeking enforcement must show that the parties formed a legally enforceable agreement. The court applied contract principles under California law. Those principles require capable parties, consent, a lawful purpose, and consideration—something exchanged as part of the agreement. Federal law also requires that the settlement be complete and that the parties or authorized representatives directly agree to be bound.

The court further explained that an oral settlement can be enforceable even if the parties planned to sign a later written agreement. A party cannot avoid an oral settlement reached before the court merely by refusing to sign a written agreement that reflects the oral terms.

Court’s analysis

The court found that the United States met its burden. It found no indication that Alicea was incapable of entering a contract. It found evidence of consent in the settlement conference minutes, the email confirmation, the notice of settlement, the lawyers’ status report, and Alicea’s own statement that he initially agreed verbally to a proposed $100,000 settlement.

The court concluded that exchanging $100,000 for a release of claims had a lawful purpose and provided consideration. It also found that Alicea directly agreed to be bound. When the court asked him at oral argument whether he had agreed to settle the case for $100,000 with a release to the United States, Alicea answered, “I did.” The court found that the settlement terms—payment of $100,000 in exchange for a release—were not reasonably disputed.

Alicea argued that his lawyers had not adequately explained important details, including that the settlement would be used to pay medical and legal bills and that the United States would not accept responsibility. He also said he had felt overwhelmed and uninformed during the settlement conference and had later told his lawyers that he did not agree to the settlement. The court said it was unfortunate that Alicea felt uncomfortable and believed his lawyers had not helped him make an informed decision. But it concluded that his arguments amounted to a change of heart after agreeing to the settlement, which did not allow him to avoid the agreement.

Disposition

The court GRANTED the United States’ motion to enforce the settlement agreement. It stated that the parties’ agreement required dismissal of the case with prejudice in exchange for payment of $100,000. The case was DISMISSED WITH PREJUDICE in accordance with that agreement, and the United States was ORDERED to pay Alicea $100,000 within 45 days of the order’s filing. The clerk was directed to close the file.