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Facts

  • The dispute involves the enforcement of a settlement agreement related to the distribution of assets from the estate of Mike S. Chavez, deceased. The petitioner, Michelle A. Chavez, and the respondent, Miguel Chavez, are siblings and heirs to the estate. The disagreement centers around the distribution of a property (the Rosario Property) which Michelle believed was mistakenly deeded to their father and originally belonged to their grandmother. The settlement agreement assigned the property to Miguel, which Michelle later contested, arguing there was no mutual assent, among other issues.

Procedural History

  • District Court of Santa Fe County: The court granted Miguel Chavez's motion to enforce the settlement agreement, denied Michelle Chavez's motion for reconsideration, and granted Miguel's request for attorney fees.

Parties' Submissions

  • Petitioner: Argued the settlement agreement was unenforceable due to lack of mutual assent, estoppel, unconscionability, and fraudulent inducement. Also contended she was entitled to compensation for her services and attorney fees, and that their half-sister breached her fiduciary duties as co-personal representative.
  • Respondent: Contended that substantial evidence supported the district court's finding of mutual assent for the agreement, that the petitioner was aware of the property issues before and during mediation, and that the agreement's distribution did not have to meet the "fair market value" requirement. Also argued against the petitioner's claims of unconscionability, fraud, and entitlement to attorney fees and compensation.

Legal Issues

  • Whether the settlement agreement is enforceable.
  • Whether the district court erred in finding the agreement did not have to meet the "fair market value" requirement for valuing assets distributed in kind.
  • Whether the district court erred in awarding attorney fees to the respondent.
  • Whether the petitioner is entitled to compensation for her services and attorney fees.
  • Whether the petitioner’s half-sister breached her fiduciary duties as co-personal representative.

Disposition

  • The Court of Appeals affirmed the district court's enforcement of the settlement agreement, its denial of the petitioner's motion for reconsideration, and its award of attorney fees to the respondent.

Reasons

  • Per HENDERSON, J., with DUFFY, J., and IVES, J., concurring:
    Mutual Assent: The court found mutual assent was present, as both parties had the same understanding of the agreement's terms at the time of signing (paras 3-7).
    Estoppel: The court rejected the petitioner's claim of equitable estoppel, finding she had knowledge of the property issues and failed to investigate further (paras 8-9).
    Unconscionability: The court found the petitioner's claims of unconscionability unsupported by legal argument or evidence (para 11-12).
    Fraud: The court found no evidence of fraudulent inducement to sign the agreement (paras 13-16).
    Distribution in Kind: The court agreed with the district court that the relevant statute governing the agreement allowed for distribution in kind without meeting the "fair market value" requirement (paras 17-18).
    Attorney Fees: The court found no abuse of discretion in the district court's award of attorney fees to the respondent based on the petitioner's lack of good faith (paras 19-21).
    Compensation and Attorney Fees for Petitioner: The court noted the petitioner's failure to develop a legal argument for her entitlement to compensation and attorney fees, and highlighted that the agreement specifically precluded her from receiving compensation for her services as a personal representative (paras 22-23).
    Fiduciary Duties: The court found no abuse of discretion in the district court's rejection of the petitioner's claim that their half-sister breached her fiduciary duties (paras 24-25).
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