Cited by

¶13 (2015) (agreeing that the 5 BENTZ/AYALA v. IQ et al. Decision of the Court requirements of what is now Rule 80(a) serves to “prevent disputes as to the existence and terms of agreements and to relieve the court of the

See State Farm, 257 Ariz. at 261, ¶ 21; 348, ¶¶ 4, 14–15 (2015) (accepting an offer can be done via email).

We review de novo the enforceability of a settlement agreement, ¶ 8 (2015), using general principles of contract interpretation, ¶ 14 (App. 1998).

enforceability of the settlement agreement, we employ the summary judgment standard of review.” ¶ 8 (2015).

¶ 16 (2015) (“The relationship between an attorney and client is governed by agency law principles.”); ¶ 23 (App. 2012) (explaining whether an agency relationship exists is a question of law where material facts are not in dispute).

For an agreement to be enforceable under Rule 80(d), both the terms of the agreement and the manifestation of assent, evinced by the parties themselves or through counsel, must be in writing.” ¶ 14 (2015).

¶ 8 (2015) (applying the summary judgment standard of review when the superior court “effectively granted summary judgment regarding the existence, terms, and enforceability of the parties’ settlement agreement”).

the non-prevailing party.” ¶ 8 (2015) (citing Ariz. R. Civ.

¶6 Petitioners argued the evidence showed that the Muhammads' counsel had apparent authority to settle the case on behalf of his clients.

¶ 10 (2015) (“When a 15 STAFFORD v. BURNS et al. Opinion of the Court rule’s language is unambiguous, we apply it as written.”) (citing Salazar- Mercado, 234 Ariz. at 592, ¶ 4).

DISCUSSION ¶7 The court effectively granted summary judgment regarding the estate’s valuation and the existence of the personal liability term in the parties’ settlement agreement; as a result, “we employ the summary judgment standard of review.” ¶ 8 (2015).