SAC Illinois Oil Exploration, LLC et al v. Taylor et al
Filing
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OPINION AND ORDER by Judge Terence Kern ; denying 41 Motion to Reopen Case (vah, Chambers)
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF OKLAHOMA
SAC ILLINOIS OIL EXPLORATION,
LLC, a New York Limited Liability
Company, and
MIL ENERGY CORPORATION, a New
York Corporation,
Plaintiffs,
vs.
ADAM TAYLOR, an individual, and
MID-ATLANTIC ENERGY, LLC, an
Oklahoma Limited Liability Company,
Defendants.
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No. 13-CV-153-TCK-TLW
OPINION AND ORDER
Before the Court is Plaintiffs’ Motion to Reopen Case (Doc. 41).
I.
Background
On June 16, 2014, the parties participated in a settlement conference before an adjunct
settlement judge. Following the conference, the adjunct settlement judge filed a report indicating
that the litigation had been settled. The Court entered a minute order directing the parties to file
their dismissal papers by July 16, 2014. On July 31, 2014, the parties filed a Joint Stipulation of
Dismissal (Doc. 40), whereby the “parties jointly stipulate[d] to the dismissal without prejudice of
all claims asserted . . . subject to the settlement agreement entered into by the parties herein on June
16, 2014 . . . .”
On December 5, 2014, Plaintiffs filed their motion to reopen case, moving the Court to
“reopen” the case based on an alleged breach of the settlement agreement by Defendants Adam
Taylor and Mid-Atlantic Energy, LLC (“Defendants”). Plaintiffs allege Defendants breached the
settlement agreement by failing to make the payments required. Defendants contend the Court lacks
jurisdiction to reopen the case.
II.
Analysis
Although Plaintiffs have requested to “reopen” the case, what Plaintiffs actually seek is
enforcement of the settlement agreement. Once a case has been dismissed, the district court does
not have jurisdiction to enforce the settlement agreement absent an order by the court expressing
intent to retain jurisdiction over the settlement agreement or incorporating the settlement agreement
into the terms of the dismissal. See Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 38182 (1994); Morris v. City of Hobart, 39 F.3d 1105, 1110 (10th Cir. 1994). The Kokkonen Court
noted that “[t]he judge’s mere awareness and approval of the terms of the settlement agreement do
not suffice to make them part of his order.” 511 U.S. at 381.
Here, the stipulation of dismissal filed by the parties evidences no intent that the Court retain
jurisdiction over the settlement agreement following dismissal. The stipulation, which closed the
case, was not signed by or entered by the Court. Other than noting that the dismissal is “subject to
the settlement agreement,” the stipulation does not otherwise reference the settlement agreement,
reserve jurisdiction over disputes regarding the settlement agreement, or incorporate any of its terms.
The Court neither read nor approved of the terms of the settlement agreement. The terms of the
settlement agreement were not shared with the Court until Plaintiffs filed their motion to reopen.
If the parties intended the Court to retain jurisdiction over the settlement agreement, the parties
should have expressed such intention in the stipulation of dismissal. Id. (noting that the “the
parties’ compliance with the terms of the settlement contract (or the court’s ‘retention of
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jurisdiction’ over the settlement contract)” may be one of the terms set forth in a dismissal pursuant
to Rule 41).
The Court rejects Plaintiffs’ contention that the parties expressed an intent for the Court to
retain jurisdiction in paragraph 8 of the settlement agreement which provides:
Plaintiffs and Defendants further agree that the United States District Court for the
Northern District of Oklahoma maintains venue and jurisdiction over the
enforcement of this Settlement Agreement and over any claims or defenses which
may be asserted by Plaintiffs or Defendants should this lawsuit be refiled because
of the failure of Defendants to make the timely payments referenced in paragraph 1
above.
(Pls. Reply 3) (emphasis added). In considering the very scenario in which they now find
themselves, the parties contemplated the lawsuit being refiled, not reopened. Therefore, any
intention expressed by the parties contradicts the relief now being sought by Plaintiffs. Accordingly,
the Court lacks jurisdiction to enforce the settlement agreement, and Plaintiffs’ Motion to Reopen
is denied.1
III.
Conclusion
For the reasons outlined above, Plaintiffs’ Motion to Reopen (Doc. 41) is DENIED.
IT IS SO ORDERED this 29th day of January, 2015.
1
In their reply, Plaintiffs alternatively request the Court set aside the stipulation pursuant
to Federal Rule of Civil Procedure 60(b)(1). Rule 60(b)(1) allows the Court to relieve a party
from an order based on “mistake, inadvertence, surprise, or excusable neglect.” The Court finds
that breach of a settlement agreement does not fall within any of the enumerated reasons, see
Sawka v. Healtheast, Inc., 989 F.2d 138, 140-41 (3d Cir. 1993), and Plaintiffs have offered no
other reason why relief would be warranted. Therefore, Plaintiffs’ request to set aside the
stipulation of dismissal is also denied.
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