Ashley Claxton v. Dale Adams

CourtCourt of Appeals of Georgia
DecidedSeptember 21, 2020
DocketA20A0780
StatusPublished

This text of Ashley Claxton v. Dale Adams (Ashley Claxton v. Dale Adams) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ashley Claxton v. Dale Adams, (Ga. Ct. App. 2020).

Opinion

FOURTH DIVISION DILLARD, P. J., RICKMAN and BROWN, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

DEADLINES ARE NO LONGER TOLLED IN THIS COURT. ALL FILINGS MUST BE SUBMITTED WITHIN THE TIMES SET BY OUR COURT RULES.

September 21, 2020

In the Court of Appeals of Georgia A20A0780. CLAXTON v. ADAMS.

BROWN, Judge.

In this interlocutory appeal, Ashley Claxton appeals from the trial court’s order

granting Dale Adams’ motion for reconsideration of its previous order enforcing a

settlement between Claxton and Adams. Claxton asserts that the trial court erred in

granting the motion for reconsideration and in failing to enforce the settlement

because: (1) its previous order was final and the motion for reconsideration was

untimely; (2) Adams waived arguments that were asserted in his motion for

reconsideration for the first time; (3) Adams was estopped from challenging the form

of the release because he attempted to cash the settlement check; and (4) the limited

liability release did not impermissibly release property damage claims. For the

reasons explained below, we affirm. The record shows that on May 24, 2016, Claxton struck Adams’ vehicle while

Adams was working in a construction zone; Claxton was charged with serious injury

by vehicle, reckless driving, and failure to maintain a lane. In September 2016,

Claxton’s insurer, Nationwide Affinity Insurance Company of North America

(“Nationwide”) offered to pay its policy limits of $50,000 to settle Adams’ claims in

exchange for a general release. On November 2, 2016, Adams filed a complaint

against Claxton, asserting that he was permanently injured as a result of the accident

and had incurred medical expenses in excess of $585,000. A copy of his complaint

was also served upon The Hanover Insurance Company (“Hanover”) and Progressive

Mountain Insurance Company (“Progressive”), in their capacity as uninsured motorist

carriers.

In late November 2016, Nationwide received a time-limited demand letter

from Adams’ counsel, the details of which will be explained in our analysis of

Claxton’s claim that the trial court erred by failing to enforce a settlement. On

December 19, 2016, counsel for Nationwide hand-delivered a check and other

documents aimed at accepting the time-limited settlement demand. On December 28,

2016, Adams’ counsel notified Nationwide’s counsel that it was rejecting what he

characterized as Nationwide’s counteroffer. One of the stated reasons was that

2 Mr. Adams’ offer of compromise could not have been more clear in its requirement that Nationwide deliver “a valid CHECK (not draft).” When the $50,000 instrument was presented to JPMorgan Chase Bank, N.A. (“Chase”) for payment, Chase stated that it could not provide cash in exchange for the instrument. Instead, Chase stated that the instrument had to be deposited into an account at Chase or another bank. Chase also refused to exchange the instrument for a check drawn directly against Chase’s funds. Upon further probing, Chase disclosed that the account had a limit set by Nationwide that prevented cashing any instrument in an amount higher than the pre-set limit. Since $50,000 was higher than the limit that was pre-set by Nationwide, Chase stated that it could not cash the instrument. Since the instrument exceeded the pre-set limit, it would have to be presented to Nationwide for approval, a process that Chase stated could take as long as nine (9) business days. Furthermore, Chase could not confirm that the instrument was, in fact, a check rather than a draft, but, since Chase would not cash the instrument, it was clear that the instrument was not a valid check.

...

Since this firm could not cash the instrument or exchange it for a guaranteed check drawn against Chase’s own funds, this firm could not immediately distribute funds to Mr. Adams. Mr. Adams was not willing to wait more than nine (9) business days for payment when he was accepting mere pennies compared to the true value of his case, and, rather than wait, he is accepting alternative arrangements to handle his financial situation. Nationwide had a full and fair opportunity to resolve

3 this case, and Nationwide squandered that opportunity by intentionally sending an instrument drawn against a restricted account.

The letter also rejected the “counteroffer” because “Nationwide also attempted to

impose additional terms that would have invalidated part of the requirements of Mr.

Adams’ offer of compromise.” It stated that the release provided by Nationwide was

“under seal” and would have created a presumption of sufficiency of the

consideration even though the $50,000 instrument could not be exchanged for cash

upon demand.

Claxton filed a motion to enforce the settlement, and on February 27, 2018, the

trial court granted the motion. Adams obtained a certificate of immediate review from

the trial court, and this Court denied Adams’ application for an interlocutory appeal

on April 18, 2018. On December 12, 2018, Adams filed a motion asking the trial

court to reconsider its decision to enforce the settlement, or in the alternative, to enter

a final judgment so that he could file an appeal from the order enforcing the

settlement. On June 5, 2019, the trial court granted Adams’ motion for

reconsideration because the release prepared by Nationwide constituted a

counteroffer as it sought to release “‘any and all claims’ rather than just personal

4 injury claims.” This Court subsequently granted Claxton’s application for

interlocutory appeal.

1. Claxton contends that the trial court’s initial order granting her motion to

enforce the settlement became final when the last remaining co-defendant was

dismissed from the case. According to Claxton, this rendered Adams’ motion for

reconsideration, filed more than 30 days later, untimely. We disagree.

Over a decade ago, the Supreme Court of Georgia held “[i]t is clear that,

notwithstanding the trial court’s grant of a motion to enforce a settlement, a case is

not at an end until such time as the agreement has ‘been made the judgment of the

court, thereby terminating the litigation.’ [Cit.]” Underwood v. Underwood, 282 Ga.

643, 644 (1) (651 SE2d 736) (2007). Accordingly, “the 30-day period for filing a

notice of appeal begins to run only when the trial court explicitly enters final

judgment, rather than when the trial court grants the motion to enforce the settlement

agreement.” Torres v. Elkin, 317 Ga. App. 135, 139 (1) (730 SE2d 518) (2012). In

this case, the trial court’s February 27, 2018 order granting Claxton’s motion to

enforce the settlement did nothing more than grant a motion in the pending litigation;

it therefore cannot be considered a final judgment. See Thomas v. Sheppard, 349 Ga.

App. 871, 872 (827 SE2d 60) (2019). “[T]he rule against amending or revoking a

5 judgment after the expiration of the term in which it was entered has no application

to interlocutory rulings so long as the case continues — from term to term, until final

judgment.” Union Circulation Co. v. Trust Co. Bank, 143 Ga. App. 715, 718 (1) (240

SE2d 100) (1977), rev’d on other grounds, Trust Co. Bank v. Union Circulation Co.,

241 Ga. 343, 345 (245 SE2d 297) (1978) (reversing division 2), vacated in part,

Union Circulation Co. v. Trust Co. Bank, 146 Ga. App. 612 (247 SE2d 197) (1978)

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