Rhoades v. Beck

Subsequent discovery of a lien will not negate a settled upon contract for full and final release of Defendant when there is evidence objectively establishing the existence of an agreement.

Rhoades appealed a general judgement denying her recovery for damages from a personal injury claim. Rhoades and Beck entered into a settlement agreement which included a term that held Beck not liable for any subsequent medical expense liens. The parties confirmed the terms of the settlement in an exchange of letters but the Rhoades did not sign the settlement agreement. Subsequent to the agreement between Rhoades and Beck, Medicare assessed a $22,970.62 lien against Rhoades. Rhoades refused to sign the settlement agreement unless Medicare would waive its lien. Beck argued the settlement was not dependent on any action by medicare and filed a motion to require Rhoades sign the settlement agreement. The court ordered the signing of the settlement agreement. Rhoades appealed. The Court of Appeals agreed, finding that there was a record which objectively established a meeting of the minds in which the parties agreed that Rhoades would release her claim against Beck and hold Beck not liable from all subsequent liens. Affirmed.