The First Circuit just delivered a stark warning about settlement remorse in employment cases
A Siemens employee settled her wage lawsuit during mediation, then refused to sign the paperwork. A federal appeals court made clear that won't fly.
Ann Marie Maccarone thought she could walk away from a settlement she agreed to in open court. The First Circuit Court of Appeals told her otherwise on January 29, delivering a decision that should get the attention of anyone handling employment disputes.
Maccarone had sued her former employer, Siemens Industry, over wage-and-hour violations under federal and Rhode Island law. After discovery and partial summary judgment, a jury trial was set for April 2024. But the parties headed to settlement talks first.
On March 6, 2024, the parties and their attorneys gathered for a court-supervised mediation. Maccarone joined by Zoom. After negotiations, they hammered out a deal. The magistrate judge carefully spelled out every term on the record, which was being recorded. Siemens would pay Maccarone a specific sum within about 30 days of signing the paperwork. There would be confidentiality provisions, non-defamation and no-rehire clauses, and a full release of all claims. The case would be dismissed with prejudice, each side covering its own costs.
Counsel for both sides confirmed the agreement on the record. Maccarone, listening in on Zoom with the ability to speak up, said nothing.
The court canceled the jury trial. Siemens drafted the settlement papers and sent them over for signatures.
Then Maccarone changed her mind.
She told her lawyer she would not sign. On May 21, her attorney emailed Siemens and the magistrate judge explaining that Maccarone felt pressured to settle and believed the defendant was getting away with their conduct.
The magistrate judge offered to meet about it. Maccarone wanted to talk to the district judge instead. The court told everyone the proper next step was for Siemens to file a motion to enforce the settlement.
Siemens did just that in July. Maccarone fought back, requesting a hearing and arguing there was no enforceable deal. She claimed she had been unduly influenced, that certain terms were not definite enough, and that the agreement was not properly documented because there was no court stenographer and nobody was sworn in.
The district court was not persuaded. On September 4, 2024, it granted the enforcement motion, finding the written documents accurately reflected what the parties had agreed to. The judge denied the request for a hearing, noting Maccarone had not provided any actual factual basis for her claim of undue influence. The court ordered her to sign the settlement papers and warned that refusing could mean dismissal with prejudice.
Maccarone filed a motion for reconsideration the next day, arguing she had been misled by an email from the judge's staff that she believed promised her a hearing.
The district court denied reconsideration on October 15. There was no evidence of impaired capacity or undue influence, the judge wrote. The court observed the case smacks of buyer's remorse, which does not justify undoing a knowing and voluntary settlement. The judge gave Maccarone until October 25 to sign the documents, warning again that noncompliance would lead to dismissal.
Maccarone's lawyer told Siemens in November his client was not going to sign. Siemens moved to dismiss the case in December. On February 6, 2025, the district court dismissed the case with prejudice and entered judgment for Siemens.
Maccarone appealed, arguing the district judge had erred in finding she entered a binding settlement. The First Circuit rejected that argument completely.
Circuit Judge Gelpí explained that courts strongly favor settlements as an alternative to expensive, time-consuming litigation. Oral settlement agreements are enforceable when parties mutually agree to all material terms. Refusing to sign the written version later does not change that.
At the mediation, the parties actively negotiated and agreed to material terms that were stated clearly on the record. When the magistrate judge recited those terms, Maccarone did not object, hedge, or raise concerns. Her lawyer expressly confirmed the agreement. Maccarone was right there on Zoom, able to speak, and she stayed silent.
Her later complaints about vague terms and tax consequences came only after the deal was done. Those objections were properly rejected as insufficient to undo what both sides had openly agreed to, the court found.
As for her claim that she deserved a hearing to testify about feeling pressured, the First Circuit said that argument was raised too late and lacked merit. When there is no genuine factual dispute about a settlement's existence or terms, no hearing is required. Simply wanting to testify about feeling pressured does not create a factual dispute requiring a hearing.
Then came the kicker. In its final paragraph, the First Circuit did not mince words about settlement gamesmanship. Federal judges in the five districts within the First Circuit are extremely busy, the court wrote. Just as parties to litigation expect judges to diligently manage their dockets, a federal judge's highly congested calendar cannot be manipulated by disgruntled litigants who have second thoughts after settlement.
The appeals court affirmed the lower court's judgment and awarded costs and attorney fees to Siemens.
For HR teams and employment lawyers, the message is unmistakable. Once you shake hands on a settlement during a court-supervised mediation and the terms go on the record, that deal is done. It does not matter if the employee never signs the paperwork. Buyer's remorse is not a defense, and vague feelings of pressure will not get you a do-over.
