Medical Recovery Services, LLC v. Baird

CourtIdaho Court of Appeals
DecidedDecember 18, 2024
Docket51169
StatusUnpublished

This text of Medical Recovery Services, LLC v. Baird (Medical Recovery Services, LLC v. Baird) is published on Counsel Stack Legal Research, covering Idaho Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Medical Recovery Services, LLC v. Baird, (Idaho Ct. App. 2024).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF IDAHO

Docket No. 51169

MEDICAL RECOVERY SERVICES, ) LLC, an Idaho limited liability company, ) Filed: December 18, 2024 ) Plaintiff-Appellant, ) Melanie Gagnepain, Clerk ) v. ) THIS IS AN UNPUBLISHED ) OPINION AND SHALL NOT MICHAEL BAIRD, ) BE CITED AS AUTHORITY ) Defendant. ) )

Appeal from the District Court of the Sixth Judicial District, State of Idaho, Franklin County. Hon. Mitchell W. Brown, District Judge.1

Judgment reducing award of recovery, vacated; and case remanded.

Smith, Driscoll & Associates, PLLC; Bryan N. Zollinger, Idaho Falls, for appellant.

Michael Baird; Preston, did not participate. ________________________________________________

HUSKEY, Judge Medical Recovery Services, LLC (MRS) appeals from the district court’s judgment awarding, but reducing, its amount of recovery. MRS argues the district court erred because it was legally bound to enforce the terms of the stipulated settlement between the parties and failed to do so. The district court abused its discretion in reducing MRS’s award of recovery. We vacate the judgment awarding, but reducing, MRS’s recovery and remand for proceedings consistent with this opinion. I. FACTUAL AND PROCEDURAL BACKGROUND MRS filed a complaint alleging that Michael Baird failed to pay for medical services he received from a medical provider. Subsequently, the parties filed a stipulated judgment in the

1 Contrary to Idaho Appellate Rule 36, the name of the district judge was not included on the cover page of the appellant’s brief. 1 district court, in which Baird admitted and stipulated that he was liable to MRS for unpaid medical services. The stipulation outlined the total amount due, $24,456.62, and the complaint broke down the stipulated amount as follows: principal amount owing, $12,250.00; prejudgment interest, $5,936.38; and attorney fees, $6,001.50. The stipulation also indicated that Baird could make monthly payments of $150.00 on the account. Both parties signed the stipulation, although Baird signed electronically. The district court held a hearing on the matter. During the hearing, the court was presented with an affidavit that indicated Baird had agreed to sign the stipulation electronically. The district court was concerned that Baird did not properly understand the terms of the stipulation. For example, during the hearing the district court explained to Baird that because the applicable interest rate was 7.375 percent, the $150.00 monthly payments would only apply to the interest so Baird would never pay down the principal owing. The district court also explained that if Baird allowed the district court to enter a default judgment, the court would impose only $1,225.00 in attorney fees instead of the $6,001.50 that Baird agreed to pay in the stipulation. The district court then asked Baird whether he wanted the district court to sign the judgment. Baird expressed some confusion about his options, explained that he did not understand how it was set up, could barely afford the $150.00 payment, was disabled, and was trying to get his Social Security disability payments started. Counsel for MRS stated: Your Honor, Mr. Baird, my office all the time discounts interest or freezes interest if people ask, or if there’s hardships. And so that’s not the end all be all, Mr. Baird, especially if you’re seeking disability. The court is correct, that paying 150 would just be paying interest. But I’m always open to settlement down the road, to discounting all the interest that’s accrued, anything like that, based on your circumstance. And I hope--you and I haven’t spoken, but I hope that my paralegal told you that down the road settlement is possible or stuff like that. So it’s not as bleak as-- you know, obviously, if you can pay more, you can. That 150 is a minimum as well. Because the court is correct, at 150 a month that’s just covering the interest that’s accruing. But I would just tell you, we discount interest all the time. If there’s ever an issue, give us a call. Baird then indicated that he wanted the district court to sign the judgment; the district court indicated it would do so. A month later, the district court entered a judgment in the amount of $19,679.38. In the court minutes, the district court included a footnote which stated the amount of attorney fees was reduced in accordance with the factors outlined in Idaho Rules of Civil Procedure 54(e)(3) and Sixth District Court Local Rule 8.1 from $6,001.50 to $1,225.00. MRS appealed.

2 II. STANDARD OF REVIEW A motion for the enforcement of a settlement agreement is treated as a motion for summary judgment when no evidentiary hearing has been conducted. Estate of Holland v. Metro. Prop. & Cas. Ins. Co., 153 Idaho 94, 100, 279 P.3d 80, 86 (2012). Thus, the “Court freely reviews the entire record that was before the district court to determine whether either side was entitled to judgment as a matter of law and whether inferences drawn by the district court are reasonably supported by the record.” Borley v. Smith, 149 Idaho 171, 177, 233 P.3d 102 108 (2010). III. ANALYSIS MRS argues the district court erred by failing to honor the parties’ contract and arbitrarily reducing the agreed upon amount of attorney fees.2 MRS’s position is that because the parties’ agreement was unambiguous, the district court was legally bound to enforce the terms of the contract. Baird, who appeared pro se in district court, did not participate in the appeal. This Court has held: When parties settle and compromise their disputed obligations, the settlement is binding on the parties. Stipulations are a form of judicial admission. A judicial admission obviates the necessity for proof of facts within the ambit of a distinct and unequivocal admission or stipulation so made. Perry v. Schaumann, 110 Idaho 596, 598, 716 P.2d 1368, 1370 (Ct. App. 1986) (internal quotations and citations omitted). A settlement agreement stands on the same footing as any other contract and is governed by the same rules and principles as are applicable to contracts generally. Vanderford Co., Inc. v. Knudson, 150 Idaho 664, 672, 249 P.3d 857, 865 (2011). All contracts “must be complete, definite and certain in all [their] material terms, or contain provisions which are capable in themselves of being reduced to certainty.” Seward v. Musick Auction, LLC, 164 Idaho 149, 158-59, 426 P.3d 1249, 1258-59 (2018) (quoting Unifund CCR, LLC v. Lowe, 159 Idaho 750, 753, 367 P.3d 145, 148 (2016)). In this case, the district court clarified the relevant terms of the stipulation with MRS and Baird, and Baird agreed with both the amount of the stipulated judgment and that the district court

2 Counsel for MRS is reminded that, pursuant to I.A.R. 35(e), references to the transcript and the record should be included in the body of the brief “and shall not be included as footnotes or endnotes.” 3 could enter the judgment. When the district court stated that it would sign the judgment, the court agreed to enter judgment in the amount of $24,456.62, and the parties were entitled to rely on that representation. A month later, however, the district court reduced the amount of attorney fees the parties agreed to and awarded judgment in the amount of $19,679.38.

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Related

VANDERFORD CO., INC. v. Knudson
249 P.3d 857 (Idaho Supreme Court, 2011)
BORLEY v. Smith
233 P.3d 102 (Idaho Supreme Court, 2010)
Perry v. Schaumann
716 P.2d 1368 (Idaho Court of Appeals, 1986)
Lettunich v. Lettunich
185 P.3d 258 (Idaho Supreme Court, 2008)
Unifund CCR, LLC v. Lorene K. Lowe
367 P.3d 145 (Idaho Supreme Court, 2016)
Seward v. Musick Auction, LLC
426 P.3d 1249 (Idaho Supreme Court, 2018)

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Medical Recovery Services, LLC v. Baird, Counsel Stack Legal Research, https://law.counselstack.com/opinion/medical-recovery-services-llc-v-baird-idahoctapp-2024.