## Facts

- Steven Lanci pursued an uninsured-motorist (UM) claim against his insurer, Metropolitan Insurance Co., arising out of an automobile accident.
- During settlement negotiations, Lanci (through counsel) agreed to accept $15,000 and signed a release (described in the record as a release and trust agreement) in Metropolitan’s favor.
- Lanci’s attorney sent Metropolitan a letter confirming the settlement, stating that Lanci agreed to accept $15,000 in settlement of the claim, “which sum you have represented to be the straight and/or stacked policy limits applicable to this claim.”
- The actual UM coverage limit under Lanci’s policy was $250,000, not $15,000.
- After the higher limit was discovered, Lanci refused to go forward with the $15,000 settlement and challenged the release, asserting that the agreement was based on a shared mistake about the policy limits.
- Metropolitan filed a motion in the trial court to enforce the settlement agreement and release.
- The trial court denied Metropolitan’s motion, concluding that the confirming letter showed the parties acted under a mutual mistake regarding the policy limits.
- Metropolitan appealed. The Superior Court first considered whether the appeal should be quashed as interlocutory, given prior authority stating that orders denying settlement enforcement are generally not immediately appealable.

## Issues

1. Whether the trial court’s order denying Metropolitan’s motion to enforce the settlement and release was immediately appealable as a collateral order, where the dispute would otherwise proceed to UM arbitration with limited judicial review.
2. Whether the $15,000 settlement agreement and release were enforceable when both parties negotiated and agreed under the mistaken belief that $15,000 was the applicable UM policy limit, but the actual limit was $250,000.

## Decision

- The Superior Court held that the order denying enforcement was appealable as a collateral order under the Cohen collateral-order doctrine.
- The court distinguished prior cases denying collateral-order status because, in the UM arbitration setting, later review would be limited by statute, making the claimed right (enforcement of the settlement to avoid arbitration) effectively lost if immediate review were denied.
- On the merits, the Superior Court affirmed the trial court’s refusal to enforce the settlement agreement and release.
- The court agreed that the record—especially the attorney’s confirmation letter—supported a finding that both parties shared a mistaken understanding that $15,000 represented the applicable straight and/or stacked UM limits.
- Because that mistaken assumption concerned the amount of available coverage and formed the basis for the settlement figure, the settlement and release were properly treated as voidable and not enforced.

## Legal Principles

- A non-final order may be immediately appealable under the collateral-order doctrine if it: (1) is separable from and collateral to the main cause of action; (2) involves rights that are too important to be denied review; and (3) would be effectively unreviewable if parties had to wait for a final judgment.
- Although an order denying enforcement of a settlement is often not immediately appealable in ordinary civil litigation, the collateral-order analysis can differ when the underlying dispute will proceed to statutory UM arbitration and judicial review of an arbitration award is narrow.
- In UM arbitration subject to 42 Pa. C.S. § 7302(d)(2), post-award court review is limited, supporting a conclusion that postponing review of a settlement-enforcement denial may result in loss of the claimed right to avoid arbitration.
- Settlement agreements and releases are governed by contract principles and may be set aside when both parties acted under a mutual mistake of fact concerning a basic assumption that materially affected the exchange.
- A shared mistake about applicable insurance policy limits—when those limits were represented as the basis for the settlement amount—can support rescission or refusal to enforce the release.

## Conclusion

The Superior Court of Pennsylvania held that Metropolitan could immediately appeal the denial of its motion to enforce a $15,000 UM settlement because forcing the parties into statutory arbitration would make later review of settlement enforcement largely unavailable, and it affirmed the trial court’s order because the settlement and release were based on a mutual mistake that $15,000 was the applicable UM policy limit when the true limit was $250,000.


Lanci v. Metropolitan Insurance Co., 564 A.2d 972 (1989)