Turner v. Thyssenkrupp Elevator

Background

Turner originally brought employment-related claims against Otis Elevator Company, TK Elevator Corporation, and International Union of Elevator Constructors, Local 9. The claims included race discrimination under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 1983, and the Minnesota Human Rights Act, as well as discrimination and retaliation claims under federal and Minnesota workplace-safety laws and retaliation claims under the Minnesota Whistleblower Act.

At a December 2, 2022 settlement conference, the magistrate judge stated the settlement’s material terms on the record. Turner confirmed that he heard and understood those terms, had enough time to consult with Kelley Jeanetta, was satisfied with her representation, agreed to be bound by the settlement, and was not being forced to agree. The settlement had not yet been incorporated into a dismissal because the rescission motions were filed before dismissal.

Turner’s Motions

Turner first sought to withdraw from the settlement, asserting that he had been told he had 21 days to rescind it and that he wanted more time to discuss it with his family. In his amended motions, he argued that newly discovered medical damages justified rescission. He also alleged that Jeanetta and defense counsel engaged in misconduct, including misrepresenting the effect of an earlier court order, failing to explain issues concerning a New Hire Registration Form, failing to provide a conflict-of-interest disclosure form, and presenting allegedly false or altered evidence.

Turner submitted a lab report from handwriting expert Lisa Hanson. According to Turner, Hanson concluded that he probably did not place an “X” on the New Hire Registration Form to indicate that he was a probationary apprentice and that his signature might have been forged. Turner sought a subpoena requiring production of the original form so Hanson could examine it.

Court’s Analysis

Applying Minnesota law, the court explained that a settlement is a contract and may be enforceable even if it is not written, so long as the parties agree on its essential terms. The court found that the parties reached an enforceable settlement because the material terms were stated on the record and Turner expressly agreed to them.

The court rejected Turner’s argument that his anxiety, depression, confusion, or later change of mind justified rescission. The court focused on Turner’s objective statements and found that the record showed he understood and voluntarily accepted the settlement. The court also stated that a party’s misunderstanding of advice from his own lawyer generally does not undo a settlement that the party expressly authorized.

The court further found that Turner had not shown that defense counsel made a fraudulent or material misrepresentation on which he justifiably relied. The court reasoned that Turner was represented by counsel and that the alleged misstatements about the earlier order could not justify reliance on defense counsel. It also found that Turner questioned the authenticity of the New Hire Registration Form during the settlement conference but agreed to settle anyway, making the form’s authenticity and legal significance irrelevant to rescission.

The court rejected Turner’s newly discovered evidence argument because parties cannot avoid a voluntary settlement merely because it later appears disadvantageous. It also found no need for an evidentiary hearing because the settlement terms were clear and there was no substantial factual dispute about the agreement’s existence or terms.

Rulings

The court granted Turner’s Motion for Leave to Amend only insofar as it considered all of his filings related to the rescission motions. It denied Turner’s Amended Motion to Rescind and Second Amended Motion to Rescind. It denied the Motion for Subpoena Duces Tecum and denied an evidentiary hearing.

The court enforced the December 2, 2022 settlement as memorialized on the record. It found that Turner had not brought the rescission motions in bad faith, denied a request for fees and costs on that ground, and directed the defendants to treat the full settlement amount as compensatory damages not subject to withholding. The defendants were ordered to satisfy the full settlement amount within 14 days. The court reserved jurisdiction for 30 days and stated that it would then enter final judgment.