Souza v. Ratto CA5

CourtCalifornia Court of Appeal
DecidedFebruary 18, 2026
DocketF088092
StatusUnpublished

This text of Souza v. Ratto CA5 (Souza v. Ratto CA5) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Souza v. Ratto CA5, (Cal. Ct. App. 2026).

Opinion

Filed 2/18/26 Souza v. Ratto CA5

NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIFTH APPELLATE DISTRICT

ANITA SOUZA, as Trustee, etc., F088092 Plaintiff and Appellant, (Super. Ct. No. CV-21-003139) v.

RAY RATTO, JR., et al., OPINION Defendants and Respondents.

APPEAL from a judgment of the Superior Court of Stanislaus County. John Mayne, Judge. Law Office of Henry D. Nunez and Henry D. Nunez for Plaintiff and Appellant. Fennemore, Mark D. Epstein and Michele C. Kirrane for Defendants and Respondents. -ooOoo- Anita Souza, Trustee for the Steve Souza & Anita Souza Revocable Living Trust, appeals from an order entered in favor of Ray Ratto, Jr., Ratto Bros., Inc., Ronald Ratto, and Lake Bottom, LLC (collectively, Ratto) granting Ratto’s motion for entry of judgment pursuant to a settlement. (Code Civ. Proc., § 664.6.)1 The oral settlement was intended to resolve a dispute between Souza and Ratto, who are owners of adjoining parcels of land, over Souza’s access to Ratto’s property pursuant to a recorded easement. After the settlement conference, the parties exchanged proposed written settlement agreements, but they could not agree on the terms. In granting Ratto’s motion, the trial court ordered Souza to “sign the settlement agreement proposed by the Ratto Defendants which reflect the terms of the settlement reached by the parties” at the settlement conference. On appeal, Souza contends: (1) the trial court failed to make express findings in its order granting the motion; (2) there is insufficient evidence to support findings that the parties had a meeting of the minds and agreed to all material terms in the proposed written settlement agreements; and (3) one of the settlement terms was uncertain. We conclude that Souza’s arguments are meritless. Nevertheless, because the order erroneously fails to set forth the material settlement terms, we amend the order to include an appealable judgment, reverse that judgment, and remand with directions to the trial court to enter a formal judgment setting forth the material terms of the settlement. FACTUAL AND PROCEDURAL BACKGROUND This case concerns a recorded agricultural drainage easement that Souza owns along the southern boundary of the adjacent parcels of agricultural real property that lie to the west of her parcels, which Ratto owns. The recorded easement grants Souza a drainage easement, which grants her the right to maintain a drainage ditch along the southern boundary of Ratto’s parcels which drains excess water from her property to the Stanislaus River. The recorded easement also contains an incidental easement allowing access across Ratto’s property to maintain the drainage ditch and a roadway easement

1 Undesignated statutory references are to the Code of Civil Procedure. Although the trial court failed to enter a formal judgment, we exercise our discretion to amend the order to include an appealable judgment, as stated post.

2. allowing access across an existing dirt road. Each property owner had a duty to maintain the drainage and roadway easements and the parties were to equally share the costs and expenses of reasonable repair and maintenance. This Lawsuit A dispute arose between Souza and Ratto concerning Souza’s ability to exercise her rights under the easement.2 Consequently, in June 2021, Souza initiated this action against Ratto and other defendants. Her first amended complaint, filed in March 2023, alleged the following causes of action: (1) quiet title to appurtenant easement; (2) quiet title to prescriptive easement; (3) quiet title to easement by necessity; (4) quiet title to implied easement; (5) quiet title to equitable easement; (6) declaratory relief; (7) damages from breach of express easement; and (8) injunctive relief. Souza alleged the easement agreement authorized her to access and use the easements and Ratto interfered with her ability to do so by refusing her entry onto the property. Mandatory Settlement Conference A mandatory settlement conference was held on October 16, 2023, before the Honorable John R. Mayne.3 There is no reporter’s transcript of the conference as a court reporter was not present. The minute order of the hearing (the settlement minute order) states that Ratto reached a settlement and lists the following terms: (1) “Defendants Ray Ratto, Ronald Ratto, Brandon Ratto, Ratto Brothers Inc have reached a settlement. Defendants are to pay Plaintiff $30,000 total”; (2) “Parties are to meet and confer regarding the drainage”; and (3) “Parties are to act in good faith. Defendant’s cannot

2 The dispute was over swing gates Ratto installed along three access points to their parcels. The gates remained open during business hours but were closed and locked at night. Ratto gave Souza a key to the gates, but she apparently lost it. When Ratto offered her a new key, she refused it. 3 The case was assigned to Judge Mayne for all purposes. The parties, through their attorneys, signed a consent to allow Judge Mayne to confer separately with each party during the settlement conference as required by Code of Judicial Ethics Canon 3 B(12).

3. reasonably oppose the repair. Each side is to pay 50% of each drainage issue to be resolved. Plaintiff is to give notice to Defendants of any future repair work.” The court set a motion to dismiss for December 20, 2023. The Parties’ Efforts to Memorialize the Settlement in Writing Ratto’s counsel, Mark Epstein, prepared a proposed written settlement agreement and release, which he emailed to Souza’s counsel, Henry D. Nunez, on October 24, 2023 (Ratto’s October agreement). The October agreement contained the following provisions: (1) Ratto would be required to deliver the $30,000 payment and a new key to the security gates to Souza; (2) Souza would dismiss the lawsuit against Ratto; (3) Souza would give Ratto advance notice of her intent to enter Ratto’s property or of any condition with the drainage system that she believed required maintenance or repair; (4) Ratto could decide if they or a third party would perform the requested maintenance work, and if they decided a third party should do so, they would obtain a cost estimate with the parties to equally share the cost; and (5) if Souza did not agree with the cost estimate, she could obtain her own cost estimate and the parties would discuss in good faith the best course of action to address the maintenance or repair issue. It also included a release, a Civil Code section 1542 waiver, and other provisions such as no admission of liability, the binding effect of the agreement, costs, governing law, representation by and consultation with counsel, construction of the agreement, authorization, amendments, execution, severability, headings and captions, attorney fees, and entire agreement. Epstein sent Nunez another email on October 30, 2023, as he had not heard from Nunez. According to Epstein, Nunez called him that day to say he was expecting to speak with Souza and her sons within the next week or two and to have them sign the settlement agreement, but he could not deal with the matter because he was preparing for trial. Epstein emailed Nunez again on November 17, 2023, as he had not heard from Nunez. Epstein asked Nunez to sign Ratto’s October agreement so the settlement could

4. be completed before the December 20, 2023 hearing. Receiving no response, Epstein emailed Nunez again on November 28, 2023. Nunez responded the following day that he could get back to Epstein by Thursday.

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