Ballesteros v. Ruiz

CourtDistrict Court, N.D. Illinois
DecidedApril 9, 2025
Docket1:24-cv-08518
StatusUnknown

This text of Ballesteros v. Ruiz (Ballesteros v. Ruiz) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ballesteros v. Ruiz, (N.D. Ill. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

NELSON ANDRES BARBOSA BALLESTEROS, on behalf of A.F.B.R., a minor child, No. 24 CV 8518 Petitioner, Judge Georgia N. Alexakis v.

RAQUEL MILENA RINCON RUIZ,

Defendant.

MEMORANDUM OPINION AND ORDER

On September 17, 2024, Nelson Andres Barbosa Ballesteros petitioned for the return of his minor child, A.F.B.R., to Canada from the United States, where A.F.B.R. was located with his mother, Raquel Milena Rincon Ruiz, pursuant to the Convention on the Civil Aspects of International Child Abduction (“the Convention”) and the International Child Abduction Remedies Act (“ICARA”). On January 28, 2025, the magistrate judge overseeing settlement efforts spoke to counsel for Ballesteros and counsel for Ruiz, “confirm[ed] that the case has settled,” and directed the parties “to file any settlement-related order(s)/stipulation to dismiss with the District Judge as soon as possible.” [45]. Two weeks later, after no such documents had been filed with this Court, Ruiz moved to enforce the settlement. [46]. Because the parties reached an enforceable settlement agreement on January 28, the Court grants that motion. I. Legal Standards Along with state courts, district courts of the United States have concurrent original jurisdiction over actions arising under the Convention. 22 U.S.C. § 9003. Because settlement agreements are a sort of contract, “[s]tate contract law governs

issues concerning the formation, construction, and enforcement of settlement agreements.” Beverly v. Abbott Lab’ys, 817 F.3d 328, 333 (7th Cir. 2016). II. Background Ballesteros and Ruiz are the parents of the minor child A.F.B.R. [1] ¶¶ 5–6; [27] ¶¶ 5–6. A.F.B.R. was born in Venezuela, but the family later moved to Colombia. [1]; ¶ 9 [27] ¶ 9. In August 2022, the family fled threats of violence in Colombia, moving initially to the United States and then to Canada, where, according to

Ballesteros, he sought refugee status on behalf of himself and A.F.B.R. in March 2023. [1] ¶¶ 9–11; [27] ¶¶ 9–11. Ballesteros and Ruiz ended their relationship in June 2023 but maintained an verbal parenting arrangement of A.F.B.R., who attended school in Canada. [1] ¶¶ 12– 14; [27] ¶¶ 12–14. But in December 2023, Ruiz brought A.F.B.R. to the United States, eventually coming to the Northern District of Illinois, where Ruiz and A.F.B.R. still

reside. [1] ¶¶ 14–18; [27] ¶¶ 14–18. Ballesteros, who still resides in Canada, maintains that Ruiz took A.F.B.R. to the United States without his knowledge or consent. [1] ¶ 14–15. On September 17, 2024, Ballesteros petitioned under the Convention for A.F.B.R.’s return to Canada, which Ballesteros argued was the child’s habitual residence. [1]. Through Court-appointed counsel, Ruiz contested the petition, and the Court entered a discovery schedule and set a trial date. [26], [27]. But at a status hearing on January 7, 2025, the parties orally moved to stay

discovery pending ongoing settlement discussions. [40]. The Court granted that motion and referred the parties to a magistrate judge for a settlement conference. Id.; [41]. On January 28, 2025, the magistrate judge spoke to counsel for Ballesteros and counsel for Ruiz and “confirm[ed] that the case has settled.” [45]. At that point, the magistrate judge terminated the referral. Id. All that remained was for the parties to file any settlement-related orders and/or stipulations with the Court so the case could be dismissed. Id.

Instead, on February 11, 2025, Ruiz moved to enforce the settlement agreement, asserting that Ballesteros was “attempt[ing] to renege on the settlement and [] refusing to sign the agreed order unless old terms are re-negotiated and new terms are included.” [46] ¶ 3. In his response to Ruiz’s motion, Ballesteros concedes that he “was initially in agreement with the proposed agreed order that had been circulated as of January 28, 2025” but that “he now has grave concerns about how

recent changes in federal U.S. policy towards undocumented immigrants will affect not only his ability to visit with his child, as previously intended under the terms of the draft order, as well as his son’s wellbeing and ability to remain on U.S. soil on an ongoing basis.” [51] ¶ 4 (citing Executive Order 14159, “Protecting the American People Against Invasion,” 90 Fed. Reg. 8443 (Jan. 20, 2025)). The Court held a hearing on March 17, 2025, on Ruiz’s motion. [54] During that hearing, counsel for Ballesteros conceded (twice) that the parties had reached an agreement on January 28, 2025.

III. Analysis State law governs settlement agreements, see Beverly, 817 F.3d at 333, so the Court first considers whether an agreement exists under Illinois law,1 and concludes that it does. As a preliminary matter, that Ballesteros has not actually signed the settlement agreement does not help him here, because “oral agreements are enforceable (and have been for centuries under the common law).” Elustra v. Mineo,

595 F.3d 699, 708 (7th Cir. 2010). Under Illinois law, “[o]ral settlement agreements are enforceable if there is an offer, an acceptance, and a meeting of the minds between the parties regarding the terms of the agreement.” Cnty. Line Nurseries & Landscaping, Inc., ex rel. Bankr. Tr. v. Glencoe Park Dist., 2015 IL App (1st) 143776 ¶ 33. The Court need not work through the elements of offer, acceptance, and a meeting of the minds because Ballesteros conceded those points in his briefing,

[51] ¶ 4, and at the March 17 hearing. Likewise, Ballesteros does not dispute that the essential terms of the agreement are sufficiently “definite and certain,” Quinlan v. Stouffe, 355 Ill. App. 3d 830, 837–38 (4th Dist. 2005), nor does he identify any other

1 Under the default rule the Court would apply the law of the forum state, Santa’s Best Craft, LLC v. St. Paul Fire & Marine Ins. Co., 611 F.3d 339, 345 (7th Cir. 2010), Ruiz assumes Illinois law applies, see [46] at 10, and Ballesteros does not object to this choice of law. defect to contract formation under Illinois law. And the Court can readily “ascertain the parties’ agreement from the stated terms and provisions.” Dillard v. Starcon Int’l, Inc., 483 F.3d 502, 507 (7th Cir. 2007). Indeed, Ballesteros would be hard-pressed to

mount a challenge in this regard given that, based on the uncontested facts before the Court, his attorney provided the operative draft used in settlement negotiations. [46-1] at 12; Sherwood Commons Townhome Owners Ass’n, Inc. v. Dubois, 2020 IL App (3d) 180561, ¶ 31 (any ambiguities in contract language construed against drafter). The parties have thus reached a valid settlement agreement. Ballesteros now seeks to negate that agreement because “he now has grave concerns” about federal immigration policy. [51] ¶ 4. But “[b]uyer’s remorse … cannot

undo a contract to which all parties have given their assent and for which all of the conditions precedent have been fulfilled.” Newkirk v. Vill. of Steger, 536 F.3d 771, 775 (7th Cir. 2008); see also Glass v. Rock Island Ref. Corp., 788 F.2d 450, 454 (7th Cir. 1986) (“A party to a settlement cannot avoid the agreement merely because he subsequently believes the settlement insufficient.”).

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Ballesteros v. Ruiz, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ballesteros-v-ruiz-ilnd-2025.