United States v. International Brotherhood of Teamsters
United States Court of Appeals for the Second Circuit
986 F.2d 15 (1993)
In a RICO consent decree case against the Teamsters, several union officers facing disciplinary charges settled through their attorney, who told the court he was authorized to accept the settlement on their behalf; the officers then performed some settlement requirements before their attorney told the government they wanted to resign instead. When the government's conditions for accepting the resignations, including firing the attorney, proved unacceptable, the government sought to enforce the original settlement; the officers, now with new counsel, refused to sign a revised agreement, and the district court enforced the original settlement. The officers appealed, arguing their first attorney lacked authority to settle and that the court's failure to hold a hearing on that issue denied them due process.
Whether a client may avoid enforcement of a settlement agreement by belatedly claiming that the attorney who agreed to it lacked authority to do so, where the attorney told the court he was authorized and the client continued to rely on him for over a year afterward.