Summary Judgment for Breach of Settlement Agreement Reversed Due to Issues of Fact

Globe Motor Co. v. Igdalev, 225 N.J. 469 (2016).  One of the fundamental principles of summary judgment jurisprudence is that a court cannot grant summary judgment when there are genuine disputes of material fact.  In evaluating whether such issues exist, the court is to give all reasonable inferences to the opponent of the motion.

Nonetheless, today, the Supreme Court had a case, involving the plaintiff’s attempt to enforce a settlement agreement, that required reiteration of those principles.  Justice Patterson, writing for a unanimous Court, provided a thorough recitation of those key principles, with numerous citations.  She also emphasized the importance of settlement in the judicial system.  Nonetheless, because there were disputed issues of material fact as to the meaning of the settlement agreement at issue, the Court reversed the summary judgment that plaintiff had obtained in the Law Division.

The case came to the Court because there was a dissent in the Appellate Division, whose majority voted to affirm the Law Division.  This fact-specific matter is likely not one that the Court would have accepted for review if it had discretion whether to do so, as the Court does with most of its docket.