COLLEEN KOLLAR-KOTELLY, United States District Judge.
Defendants Capital One, N.A. and Capital One Auto Finance, Inc. (collectively, "Capital One") seek the Court's enforcement of a settlement agreement between Capital One and Plaintiff Charnita Proctor. Ms. Proctor does not dispute that she entered into an agreement. Rather, she objects to its putative scope, arguing that it pertains only to a specific auto loan from Capital One.
It is helpful to begin in reference to Ms. Proctor's request for an evidentiary hearing on this motion. Ms. Proctor claims an entitlement to such a hearing "to determine whether the parties entered into a binding contract," Pl.'s Opp'n at 3 (citing, e.g., United States v. Mahoney, 247 F.3d 279, 285 (D.C. Cir. 2001)). "When there is a genuine dispute about whether the parties have entered into a binding settlement, the district court must hold an evidentiary hearing that includes the opportunity for cross-examination." Mahoney, 247 F.3d at 285.
However, such a hearing is not necessary if the Court is persuaded on the
Samra v. Shaheen Bus. & Inv. Grp., Inc., 355 F.Supp.2d 483, 494 (D.D.C. 2005). Accordingly, the Court shall proceed to consider whether Capital One has discharged its burden to prove a settlement agreement between Capital One and Ms. Proctor.
The parties urge the Court to apply District of Columbia law for the formation of contracts, in particular, settlement agreements. See Def.'s Mem. at 6; Pl.'s Opp'n at 1. The Court is unaware of any reason to do otherwise. "In the District of Columbia, an enforceable contract exists when there is an agreement about all material terms and an intention of the parties to be bound." Mahoney, 247 F.3d at 285, "In the context of settlement agreements, court [sic] have found that the amount to be paid and the claimant's release of liability are the material terms" under D.C. law. Blackstone v. Brink, 63 F.Supp.3d 68, 77 (D.D.C. 2014).
Capital One considers the material terms to consist of:
Def.'s Mem. at 6. Because this statement of material terms includes the amount to be paid and the release of liability, an agreement containing these terms would suffice under D.C. law if the parties intended to be bound by it. See Brink, 63 F.Supp.3d at 77.
Ms. Proctor does not dispute Capital One's characterization of the material terms, except insofar as the settlement agreement could be read to include a release of claims she may have that are unrelated to the specific auto loan presently at issue. See Pl.'s Opp'n at 2. She objects in particular to language in Paragraph 6 that would require her, in pertinent part, to release [redacted] Confidential Settlement Agreement and Release of Claims, ECF No. 18-2, Ex. 2 ¶ 6; see also Pl.'s Opp'n at 2. She is especially concerned about any claims against Capital One that she may pursue related to three charged-off credit cards. See PL's Opp'n at 2. Although Capital One's correspondence suggests that the parties' oral agreement included [redacted] ECF No. 18-2, Ex. 1 Proctor006; see also Confidential Settlement Agreement and Release of Claims, ECF No. 18-2, Ex. 2 ¶ 2 ([redacted]), Capital One confirms that the parties did not discuss anything about charged-off credit cards, see Def.'s Reply at 4-5. In turn, the agreement drafted by Capital One expressly identifies only the car loan as a claim at issue, for purposes of this litigation and the settlement agreement. See Confidential Settlement Agreement and Release of Claims, ECF No. 18-2, Ex. 2 (recitals). Accordingly, the Court construes the parties as agreeing only to release claims that could arise related to this auto loan.
The parties concede their intention to enter into a settlement. Def.'s Mem, at 6; PL's Opp'n at 1. Moreover, Capital One's execution of the Confidential Settlement Agreement and Release of Claims, ECF No. 18-2, Ex. 3, demonstrates Capital One's intention to be bound by this particular document, which it represents as containing the material terms to which the parties agreed in their discussions orally and by email.
The Court finds that Ms. Proctor and Capital One agreed to a settlement agreement that does not include [redacted] and contains a release only as to the car loan expressly at issue in this litigation and in the settlement agreement. The settlement agreement shall adopt language in Paragraphs 2 and 6 that more clearly indicates the limited scope of the agreement. The settlement agreement also shall be revised in Paragraph 4 to omit [redacted], as Ms. Proctor and Capital One agreed.
Pursuant to the terms of the parties' settlement agreement, Ms. Proctor shall file a Notice of Dismissal of Capital One only in accordance with Paragraph 2, as amended.
An appropriate Order accompanies this Memorandum Opinion.