What is the standard of review applied in a settlement agreement?

California, United States of America


The following excerpt is from Gault v. Sass Elec., Inc., D069107 (Cal. App. 2016):

The parties disagree on the proper standard of review. The only conflicting evidence in the record is the parties' declarations discussing each individual's subjective understanding and intention pertaining to the payment provisions, but "evidence of the undisclosed subjective intent of the parties is irrelevant to determining the meaning of contractual language." (Winet v. Price (1992) 4 Cal.App.4th 1159, 1166, fn. 3.) Because

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there is no conflict in competent extrinsic evidence, we independently construe the settlement agreement and stipulated judgment. (Ibid.)

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