Brave Law Firm v. Truck Accident Lawyers Group

CourtCourt of Appeals for the Tenth Circuit
DecidedFebruary 8, 2021
Docket20-3049
StatusUnpublished

This text of Brave Law Firm v. Truck Accident Lawyers Group (Brave Law Firm v. Truck Accident Lawyers Group) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brave Law Firm v. Truck Accident Lawyers Group, (10th Cir. 2021).

Opinion

FILED United States Court of Appeals UNITED STATES COURT OF APPEALS Tenth Circuit

FOR THE TENTH CIRCUIT February 8, 2021 _________________________________ Christopher M. Wolpert Clerk of Court BRAVE LAW FIRM, LLC,

Plaintiff - Appellant,

v. No. 20-3049 (D.C. No. 6:17-CV-01156-EFM-JPO) TRUCK ACCIDENT LAWYERS (D. Kan.) GROUP, INC.; BRAD PISTOTNIK LAW, P. A.; BRADLEY A. PISTOTNIK,

Defendants - Appellees. _________________________________

ORDER AND JUDGMENT * _________________________________

Before HARTZ, KELLY, and EID, Circuit Judges. _________________________________

Brave Law Firm, LLC (“Brave”), appeals from the district court’s judgment

enforcing a settlement agreement in Brave’s suit against Truck Accident Lawyers

Group, Inc., Brad Pistotnik Law, and Bradley A. Pistotnik (collectively, “Pistotnik”).

Exercising jurisdiction under 28 U.S.C. § 1291, we affirm.

* After examining the briefs and appellate record, this panel has determined unanimously to honor the parties’ request for a decision on the briefs without oral argument. See Fed. R. App. P. 34(f); 10th Cir. R. 34.1(G). The case is therefore submitted without oral argument. This order and judgment is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1. BACKGROUND

Brave and Pistotnik are competing personal-injury law firms in Kansas. Brave

sued Pistotnik for false advertising and unfair competition under the Lanham Act, as

well as for violations of Kansas law. It alleged that certain print, video, and Internet

advertisements stating that Pistotnik had obtained large verdicts or settlements were

false or misleading for various reasons.

As relevant to this appeal, Brave challenged Pistotnik’s advertisements

regarding a certain $9 million settlement (the Settlement). During the litigation,

Brave “agreed to dismiss this lawsuit upon receipt of authenticated, admissible proof

that the $9,000,000 . . . settlement advertised by all of the Defendants occurred as

advertised.” Id. Vol. 5 at 991. Pistotnik produced documentation showing that

Bradley Pistotnik was counsel in a suit that resulted in a $9.5 million settlement for

an injured man, his wife, and their two minor children. But Brave declined to

dismiss the case, stating that the production did not satisfy its offer because the

settlement involved four clients, rather than one. 1

Pistotnik moved to enforce the settlement agreement, and Brave argued in

response that Pistotnik’s pleadings admitted that he had advertised the Settlement as

belonging to one client. After holding an evidentiary hearing, the district court ruled

in favor of Pistotnik. Rejecting Brave’s position, it held that “[t]he settlement offer

requires [Pistotnik] to submit proof of a settlement that is consistent with its

1 The discrepancy between the $9 million advertised amount and the $9.5 million settlement amount is not at issue. 2 advertisements. The Court can make its own conclusions regarding what the

advertisements say, and it finds that they do not advertise obtaining a settlement for a

single client.” Aplt. App., Vol. 10 at 1754 n.11. The court therefore granted

Pistotnik’s motion to enforce the settlement agreement and dismissed the case.

Also relevant to this appeal, the magistrate judge entered a protective order

preventing the parties from disclosing documents designated as confidential. Upon

Brave’s motion to compel, the magistrate judge required Pistotnik to produce

documents concerning the Settlement, subject to the protective order. The documents

showed the caption of the case underlying the Settlement, and with that information,

Brave procured copies of the filings directly from that court. Pistotnik moved for a

protective order requiring Brave to maintain the confidentiality of the former clients’

identities and precluding it from publicly connecting the court records it obtained to

the Settlement. Brave objected, asserting that the information it obtained from the

originating court was public information.

The magistrate judge granted Pistotnik’s motion, holding:

In the abstract, plaintiff is correct that the policy in this district is not to protect from disclosure documents that are available to the public. But the issue here is more complex. As a matter of basic fairness, practicality, and respect for court orders, the court holds a litigant may not use confidential information that the court has specifically ruled subject to the court’s protective order to obtain documents and then use those documents to publicize the very confidential information that the court protected. Aplt. App. Vol. 7 at 1231 (footnote omitted). Noting that “the court . . .

contemplated the identity of the parties to the underlying settlement would be

protected,” the magistrate judge stated, “[t]he court will not permit the plaintiff to

3 make an end-run around its orders.” Id. at 1232. Brave filed Fed. R. Civ. P. 72(a)

objections with the district court, which affirmed the magistrate judge’s order.

Brave now appeals from the decisions enforcing the settlement agreement and

upholding the confidentiality order.

DISCUSSION

I. Enforcement of Settlement Agreement

“A trial court has the power to summarily enforce a settlement agreement

entered into by the litigants while the litigation is pending before it.” United States v.

Hardage, 982 F.2d 1491, 1496 (10th Cir. 1993). “We review a district court's

decision to enforce a settlement agreement for abuse of discretion.” Walters v.

Wal-Mart Stores, Inc., 703 F.3d 1167, 1172 (10th Cir. 2013). “An abuse of

discretion occurs when the district court based its decision on an erroneous

conclusion of law or where there is no rational basis in the evidence for the ruling.”

Shoels v. Klebold, 375 F.3d 1054, 1060 (10th Cir. 2004) (internal quotation marks

omitted). Under the abuse-of-discretion standard, “[w]e will leave the district court’s

decision undisturbed unless we have a definite and firm conviction that the court

made a clear error of judgment.” Walters, 703 F.3d at 1172.

Brave first argues that the district court erred in declining to consider

Pistotnik’s alleged admissions, in several pleadings and filings in the litigation, that

the Settlement involved one client. It asserts that judicial admissions are binding at

later stages in the litigation and that the court erred in “substitut[ing] its own opinion

in lieu of admitted facts,” Opening Br. at 28. We disagree. The terms of the

4 settlement offer are unambiguous, based on the Settlement “as advertised.” Aplt.

App. Vol. 5 at 991. The district court did not err in evaluating the advertisements

without regard to the parties’ characterizations thereof. And it did not err in

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Related

Shoels v. Klebold
375 F.3d 1054 (Tenth Circuit, 2004)
Richison v. Ernest Group, Inc.
634 F.3d 1123 (Tenth Circuit, 2011)
Walters v. Wal-Mart Stores, Inc.
703 F.3d 1167 (Tenth Circuit, 2013)
United States v. Hardage
982 F.2d 1491 (Tenth Circuit, 1993)

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