## Facts

- Michael Jordan and Karla Knafel had an intimate relationship in the late 1980s–early 1990s.
- Knafel asserted that Jordan agreed to pay her $5 million upon his retirement in exchange for her agreement not to file a paternity suit and to keep their relationship confidential.
- Jordan denied owing $5 million and alleged Knafel sought money by threatening to publicize the relationship; he sought declaratory and injunctive relief.
- Knafel counterclaimed for breach of the alleged confidential settlement agreement.
- DNA testing later indicated Jordan was not the father of Knafel’s child.
- After an earlier appeal reinstated both sides’ pleadings for further proceedings, the circuit court, on a developed record, granted Jordan summary judgment on Knafel’s counterclaim and on Jordan’s amended complaint, finding the alleged agreement unenforceable due to fraud or mutual mistake tied to paternity.

## Issues

1. Whether summary judgment was proper because any alleged settlement agreement was unenforceable due to fraudulent inducement or mutual mistake concerning paternity.
2. Whether Knafel raised a genuine issue of material fact as to the validity and effect of paternity testing and the elements of fraud or mutual mistake.
3. Whether summary judgment on Jordan’s declaratory claim was improper based on alleged factual disputes concerning extortion-related allegations.
4. Whether the trial court abused its discretion in denying Knafel’s motions to compel additional discovery, including Jordan’s deposition and document production.

## Decision

- The appellate court affirmed summary judgment for Jordan on Knafel’s counterclaim and on Jordan’s amended complaint.
- The court held the alleged agreement was unenforceable because its central premise—Jordan’s paternity—was false, making the agreement invalid under either:
  - fraudulent inducement (if Knafel knowingly misrepresented paternity), or
  - mutual mistake of material fact (if both parties mistakenly believed Jordan was the father).
- The court rejected Knafel’s arguments that disputes about testing or intent created a material factual issue sufficient to avoid summary judgment.
- The court affirmed the denial of Knafel’s discovery motions, finding no abuse of discretion because additional discovery would not have created a material factual dispute on the dispositive paternity/fraud/mistake grounds.
- The court did not need to decide whether Knafel’s conduct legally constituted extortion to affirm, because contract unenforceability on fraud/mistake grounds was dispositive.

## Legal Principles

- Summary judgment is appropriate when the record shows no genuine issue of material fact and the movant is entitled to judgment as a matter of law.
- A contract induced by a false statement of material fact, made to secure the other party’s assent, is unenforceable by the party committing the fraud.
- A contract is unenforceable when both parties share a mutual mistake about a material fact that is a fundamental assumption of the agreement.
- When a contract’s essential premise is disproved on an undisputed record, disputes that would not alter the enforceability analysis do not bar summary judgment.
- Trial courts have discretion over discovery; denial of additional discovery is proper when the requested material would not affect resolution of the controlling issues.

## Conclusion

The appellate court upheld judgment for Jordan because the alleged $5 million confidentiality/paternity settlement, premised on Jordan’s paternity, could not be enforced once DNA evidence disproved paternity, rendering the agreement invalid under fraudulent inducement or mutual mistake and leaving Knafel without a contract claim.


Jordan v. Knafel, 378 Ill. App. 3d 219, 879 N.E.2d 862 (Ill. App. Ct. 2007)