A contentious legal battle over a personal injury claim has taken a dramatic turn, as the Court of Appeal of the State of California reversed a trial court's decision regarding a settlement judgment. On July 16, 2024, Maya Endrawes filed an appeal in the Second Appellate District against Briaunna Mitchell, challenging the validity of a stipulated judgment based on an alleged counteroffer rather than an acceptance.
The case began when Maya Endrawes was involved in a vehicular collision with Briaunna Mitchell, who was driving a car owned by her parents, Harold and Tonia Mitchell. Following the incident, Endrawes filed a complaint for damages against Mitchell and her parents. While Briaunna and Harold Mitchell responded to the complaint jointly, Tonia did not file an answer.
On June 3, 2022, Endrawes made an offer to compromise under Section 998 of the Code of Civil Procedure, proposing a $210,000 judgment against Briaunna Mitchell. This offer included specific terms for acceptance: it had to be signed within 30 days or it would be deemed withdrawn. On the 28th day after the offer was made, Mitchell’s counsel signed both the statement of acceptance and a separate "NOTICE OF ACCEPTANCE OF OFFER TO COMPROMISE," which included additional language that could release other parties from liability.
Endrawes objected to this notice eleven days later, arguing that it constituted a counteroffer rather than an unequivocal acceptance under Section 998. The trial court initially sustained Endrawes' objection but focused on finalizing the form of judgment rather than addressing whether there had been an actual settlement agreement. Despite ongoing objections from Endrawes asserting that no valid settlement existed due to the counteroffer, the trial court eventually signed off on a stipulated judgment prepared by Mitchell’s counsel on December 29, 2022.
Endrawes then filed a motion to vacate this judgment on April 27, 2023. She argued that since Mitchell’s response was essentially a counteroffer and not an unequivocal acceptance, no binding agreement had been formed. However, this motion was denied by the trial court on June 12, 2023.
In its review, the Court of Appeal found that because Mitchell’s notice included additional conditions not present in Endrawes’ original offer—potentially releasing other parties from liability—it constituted a counteroffer. Citing precedents like Bias v. Wright (2002), where similar conditional acceptances were deemed counteroffers invalidating settlements under Section 998 offers, the appellate court ruled that such conditions rendered any purported acceptance void on its face.
Consequently, the appellate court concluded that denying Endrawes' motion to vacate lacked reasonable basis given her prompt actions and lack of demonstrated prejudice against Mitchell due to minor delays. The order denying her motion was reversed with instructions for the trial court to grant it upon remand.
Representing Maya Endrawes were El Dabe Ritter Trial Lawyers and S. Edmond El Dabe along with Cynthia Goodman; MacDonald & Cody with Edye A. Hill represented Briaunna Mitchell.
The case was presided over by Judge Henry J. Walsh in Ventura County Superior Court under Case ID No. B330916.