How Detailed Must Language Be in Dismissal Entry to Enforce Terms of Settlement Agreement Later?

Infinite Security Solutions, LLC v. Karam Properties I, Ltd., Case Nos. 2013-1671 and 2013-1795

Sixth District Court of Appeals (Lucas County)

ISSUE: Is a trial court's dismissal entry that does not include the terms of a settlement agreement or expressly reserve jurisdiction to enforce the settlement an unconditional dismissal?

Editor's Note: The Supreme Court determined that a conflict exists between multiple appellate districts on this issue and ordered that the certified-conflict case (2013-1671) be consolidated with the appeal from the Travelers Indemnity Company (2013-1795) for oral arguments.