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July 22, 2009

Iowa Court of Appeals Finds No Agreement to Settle Claim

In its opinion in Eaton Corporation v. Branson, filed June 17, 2009, the Iowa Court of Appeals found that the employer was not entitled to specific enforcement of what they claimed was a legally enforceable agreement to settle a claim for a work injury claim.

While the self-insured employer and its workers’ compensation claims administrator believed that the parties had reached a legal agreement to settle the claim, the injured worker testified that he had simply said that he wanted to look over the settlement papers, and that he would then make up his mind. The Court found that there was not sufficient evidence of an enforceable legal contract. Noting that the employer would have to produce “clear, satisfactory, and convincing evidence” that a “meeting of the minds” existed, sufficient to show a valid, enforceable contract, the Court found that the proof did not meet the employer’s burden.

The Court of Appeals affirmed the Iowa District Court ruling that there was no enforceable settlement. No decision has been made on whether to publish the opinion.

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