In Aki v. University of California Lawrence Berkeley National Laboratory, the plaintiff agreed to resolve his disability discrimination and failure to accommodate claims against his former employer following a court settlement conference. In open court, the plaintiff’s attorney recited that the plaintiff agreed to a $45,000 payment in exchange for a general release of claims and the plaintiff confirmed his understanding and acceptance of those terms to the judge.

After defense counsel reduced the settlement terms to writing and requested that the plaintiff execute the settlement agreement, the plaintiff refused. The plaintiff asserted that he intended only to release the disability discrimination and failure to accommodate claims against his former employer, and not to enter into a general release of claims. Defendant sent the plaintiff a $45,000 check and moved the federal district court to enforce the settlement agreement. The federal district court in California held that the settlement was enforceable, notwithstanding the lack of a written settlement agreement, because the terms were agreed upon and consented to, the agreement had a lawful objective and it was supported by lawful consideration.