Byrum v. Bear Investment Co.

WILKINSON, Circuit Judge:

This case raises questions about when enforceable settlement agreements have been formed. The district court concluded that Barney and Elizabeth Byrum had tendered a valid acceptance to Bear Investment Company’s offer to settle their dispute over a parcel of land when the By-rums sent the company a check for the amount specified in the offer and a general release. Although the check sent by the Byrums contained the words “under protest” and the general release stated that the Byrums were “under extreme pressure” to settle in order to save their land, the district…