Former worker claims she's entitled to a six-figure sum
The case of Siri v. Sutter Home Winery, Inc. arose when the plaintiff brought a suit for wrongful termination in violation of public policy against her former employer, Sutter Home Winery, Inc., which was doing business as Trinchero Family Estates.
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In 2019, the company offered to compromise in line with section 998 of California’s Code of Civil Procedure. Under the offer, the company would pay the plaintiff $500,000 in exchange for the full settlement of her claims.
The plaintiff provided a notice of conditional acceptance. These conditions involved her rights to seek clarification of three issues, including her alleged right to recover prejudgment interest. She claimed that her acceptance of an offer for a higher sum than what the company previously offered would trigger the cost-shifting provisions of section 3291 of California’s Civil Code and would entitle her to recover prejudgment interest of around $379,000. She filed her objections to the offer with the court.
The company brought a motion to enforce the settlement agreement in light of the plaintiff’s conditional acceptance. The trial court granted the company’s motion. The court found that the “conditional acceptance” was absolute despite its title and that this acceptance created a binding settlement.
The plaintiff requested prejudgment and postjudgment interest. The trial court denied this request and dismissed her claims. She appealed, arguing that the trial court exceeded its authority when it decided whether the parties’ offer and acceptance formed a binding agreement.
The California Court of Appeal for the First District reversed the trial court’s judgment of dismissal and returned the case to the lower court for further proceedings. The trial court improperly determined that a binding settlement agreement was reached in line with the section 998’s procedures, the appellate court said.
The plaintiff’s acceptance was conditional since it depended on the addition of new terms to the proposed settlement, the appellate court explained. These additional terms made the acceptance conditional even if they involved the plaintiff’s rights to have the trial court consider certain arguments, which the court ultimately rejected.
An effective acceptance should be absolute and unqualified, the appellate court said. In this case, the plaintiff’s conditional acceptance did not create an agreement that could be enforced under section 998, the appellate court concluded.
