AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• In October 2005, Plaintiff Robert James Bransford (Jim) sued his brother, Defendant Michael Bransford (Michael), and Michael's limited liability company, Rancho Verano, LLC, for breach of a land contract. The court awarded Jim the net profits from the sale of the land, and the parties later agreed to a settlement conference for the remaining issues, resulting in a $350,000 settlement in October 2006. Following a dispute, in May 2007, the parties executed a second settlement agreement with a "Full and Complete Release of Claims" provision. Nearly three years later, Jim sought to modify the 2006 settlement agreement, claiming a miscalculation of net profits due to a discrepancy in development costs. Michael responded by seeking court costs and attorney fees, asserting Jim breached the 2007 settlement's complete release clause by reopening litigation (paras 2-4).

Procedural History

• District Court of Santa Fe County, Barbara J. Vigil, District Judge: Denied Plaintiff's motion to modify the 2006 settlement agreement and awarded Defendant Michael Bransford reasonable costs and attorney fees (para 1).

Parties' Submissions

• Plaintiff: Contended that the district court erred in applying the law of rescission to the facts of the case and argued that the general release was not binding on the parties regarding the matter at hand (para 6).
• Defendant: Asserted that Plaintiff breached the complete release contained in the 2007 settlement agreement by seeking to reinstate litigation on the 2006 settlement agreement, thus entitling the Defendant to recover costs and attorney fees (para 5).

Legal Issues

• Whether the district court erred in granting summary judgment on the motion to modify the settlement agreement.
• Whether the district court erred in awarding Defendant Michael Bransford court costs and attorney fees.

Disposition

• The Court of Appeals affirmed the district court's decision to grant summary judgment on the motion to modify the settlement agreement.
• The Court of Appeals reversed the district court's decision to award Defendant Michael Bransford court costs and attorney fees and remanded for further proceedings (para 15).

Reasons

• Per J. MILES HANISEE (RODERICK T. KENNEDY, Chief Judge, and MICHAEL E. VIGIL, Judge concurring): The Court of Appeals concluded that the district court correctly granted summary judgment on the motion to modify the settlement agreement, as the Plaintiff sought reformation of the contract without showing that the contract did not represent the agreement the parties intended to make. The Court found no genuine issue of material fact regarding the modification issue, thus entitling the Defendant to summary judgment as a matter of law. However, the Court found that the district court erred in awarding court costs and attorney fees to the Defendant because the 2007 settlement agreement's general release provision lacked sufficient specificity to conclude that it applied or was intended to apply to Rancho Verano, LLC as a corporate defendant. The Court referenced a recent decision in Benz v. Town Center Land, LLC, to support its reversal on the issue of attorney fees and costs, indicating that without specific designation or extrinsic evidence, the general release did not apply to Rancho Verano, LLC (paras 7-14).