Florida Appellate Court Reverses Ruling on Settlement Agreement in Neeld v. Combs
Introduction
The Fifth District Court of Appeal of Florida recently issued a ruling in Neeld v. Combs, a case involving the enforceability of a proposal for settlement in an automobile negligence lawsuit. The case centered on whether a settlement agreement was valid despite the plaintiff’s claim that his attorney mistakenly submitted the offer for $100,000 instead of $1,000,000. The appellate court ruled in favor of Neeld, finding that a binding settlement had been formed and that the trial court erred by allowing Combs to withdraw the settlement proposal after acceptance.
This decision clarifies the application of Florida’s settlement statute (Section 768.79, Florida Statutes) and Florida Rule of Civil Procedure 1.442, particularly in cases involving alleged unilateral mistakes in settlement offers.
Case Background
The Underlying Accident and Lawsuit
The case arose from a 2017 motor vehicle accident, in which Combs sued Neeld for negligence. Combs sought damages for injuries sustained in the crash.
The Settlement Offer and Dispute
Combs’ attorney submitted a proposal for settlement for $100,000, believing it to be an offer for policy limits ($1,000,000). Neeld accepted the $100,000 settlement within the 30-day statutory period.
After acceptance, Combs’ attorney claimed the $100,000 figure was an error and attempted to withdraw the settlement and submit a revised offer. Neeld refused, arguing that a binding contract had already been formed under Florida’s offer of judgment statute (Section 768.79, Florida Statutes).
Trial Court Ruling
The trial court ruled in favor of Combs, allowing him to withdraw the proposal for settlement and set aside the acceptance. The court reasoned that the mistake created an issue of fairness and due process that warranted rescinding the settlement agreement. Neeld appealed, arguing that Florida law does not permit withdrawal of a settlement once it has been accepted under the statutory framework.
Appellate Court’s Analysis and Ruling
The Fifth District Court of Appeal reversed the trial court’s ruling, finding that:
A Binding Settlement Agreement Was Formed
Under Section 768.79, Florida Statutes, a proposal for settlement must:
- Be in writing.
- Clearly state the amount offered.
- Be accepted within 30 days.
Neeld accepted the offer in writing before the deadline, forming a valid and enforceable contract. The appellate court cited Suarez Trucking v. Souders, 350 So. 3d 38 (Fla. 2022), which held that a properly accepted settlement offer creates an enforceable agreement regardless of later disputes over intent.
A Party Cannot Withdraw a Proposal for Settlement After Acceptance
Florida law only allows withdrawal of a proposal for settlement before acceptance. Because Combs did not withdraw his offer before Neeld’s acceptance, the trial court had no legal basis to set aside the settlement.
The Attorney’s Alleged Mistake Did Not Invalidate the Agreement
The court rejected Combs’ claim that the settlement was invalid due to a unilateral mistake. Under Florida contract law, a party’s subjective intent is irrelevant if the written terms are clear. The terms of the proposal for settlement controlled, and Combs’ after-the-fact claim of mistake could not undo the agreement.
The Court Rejected the Fairness Argument
The appellate court found that allowing parties to revoke settlement agreements based on unilateral mistakes would undermine the integrity of Florida’s settlement statute. The statutory process relies on strict deadlines and objective terms, not subjective intent.
Conclusion of the Ruling
The appellate court reversed the trial court’s order, ruling that the settlement was valid and enforceable. The case was remanded for further proceedings, requiring Combs to honor the $100,000 settlement agreement.
Key Legal Takeaways from Neeld v. Combs
Florida’s Settlement Laws Favor Strict Enforcement
The ruling reinforces that once a proposal for settlement is accepted within the statutory timeframe, it creates a binding contract. Courts will not allow withdrawal unless there is fraud, misrepresentation, or another valid contract defense.
The Importance of Accuracy in Settlement Offers
Attorneys must carefully review settlement offers before submission. Courts do not allow post-acceptance revisions, even if the mistake was unintentional.
Objective Contract Terms Control Over Subjective Intent
Even if a party intended a different settlement amount, the written terms govern. Subjective misunderstandings or verbal clarifications outside the written proposal for settlement are irrelevant.
Florida Law Discourages Gamesmanship in Settlements
The ruling prevents plaintiffs from backing out of unfavorable settlements after acceptance. This ensures fairness and predictability in Florida’s legal system.
Implications for Future Cases
For Defendants and Insurance Companies
Defendants should quickly accept favorable settlement offers before plaintiffs reconsider. If a plaintiff tries to withdraw a settlement after acceptance, courts will likely enforce the agreement.
For Plaintiffs and Their Attorneys
Attorneys must double-check all proposal for settlement submissions to avoid clerical errors. Plaintiffs cannot assume they can renegotiate or withdraw a proposal for settlement after acceptance.
How a Florida Civil Litigation Attorney Can Help
An experienced Florida civil litigation attorney can:
- Ensure settlement agreements are properly drafted and submitted.
- Challenge attempts to withdraw or modify accepted settlements.
- Defend clients against unfair settlement tactics.
- Represent clients in appeals involving settlement disputes.
At Bonderud Law, we assist clients in negotiating, enforcing, and challenging settlements in Florida civil cases. If you need legal guidance on a settlement dispute, contact us today for a free consultation.
Conclusion
The Fifth District Court of Appeal’s ruling in Neeld v. Combs establishes that a properly accepted settlement offer is binding and cannot be withdrawn based on a unilateral mistake. This decision reinforces Florida’s strict enforcement of settlement agreements, ensuring that parties cannot back out after acceptance.
If you are involved in a settlement dispute or civil litigation in Florida, consulting with an experienced attorney can help protect your rights and ensure a fair and enforceable outcome.
