Christina Sar v. REV RECREATION GROUP, INC., d/b/a MIDWEST AUTOMOTIVE DESIGNS LLC

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted May 26, 2026*
Decided May 26, 2026
Before
AMY J. ST. EVE, Circuit Judge
CANDACE JACKSON-AKIWUMI, Circuit Judge
NANCY L. MALDONADO, Circuit Judge
No. 25-2535
CHRISTINA SAR,
Plaintiff-Appellant,
v.
REV RECREATION GROUP, INC.,
d/b/a MIDWEST AUTOMOTIVE
DESIGNS LLC,
Defendant-Appellee.
Appeal from the United States District
Court for the Northern District of
Indiana, South Bend Division.
No. 3:23-CV-1050 DRL-SJF
Damon R. Leichty,
Judge.
O R D E R
Christina Sar sued her employer, REV Recreation Group, Inc., for sex
discrimination and retaliation under Title VII. See 42 U.S.C. § 2000e-2. The parties
reached a settlement agreement, but Sar refused to sign it. REV then moved to enforce
* We have agreed to decide the case without oral argument because the briefs and
record adequately present the facts and legal arguments, and oral argument would not
significantly aid the court. F ED. R. A PP . P. 34(a)(2)(C).
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with F ED. R. APP . P. 32.1

-- 1 of 4 --

No. 25-2535 Page 2
the settlement agreement. After an evidentiary hearing, the district court found that the
parties reached a meeting of the minds as to each material term and granted the
defendant’s motion to enforce the agreement. The district court then granted REV’s
motion to dismiss the case with prejudice, and Sar appeals. We affirm.
In November 2023, Sar sued REV in Indiana state court, alleging sex
discrimination and retaliation. REV removed the case to federal court. One year later,
Sar and REV participated in mediation but did not reach an agreement. Sar’s attorney,
Myra Reid, continued to negotiate with REV’s counsel, Christina Mallatt. Mallatt sent
Reid a written copy of a proposed settlement agreement. A few weeks later, Reid sent
back a revised version of the agreement, explaining that Sar wanted a specific employee
exempted from the release of claims and wanted the agreement to specify how
attorney’s fees would be remitted. Reid said that Sar would sign the agreement if the
changes were made. Mallatt made the changes and sent the revised agreement back. But
a week later, Sar emailed Mallatt, saying she would not sign the agreement.
REV then filed a motion to enforce the settlement agreement, and Reid filed a
motion to withdraw as Sar’s counsel. The court held a hearing in March 2025. Reid
testified that during negotiations, Sar shared only two objections to REV’s proposed
settlement agreement—she wanted a specific employee exempted from the release and
the agreement to explain how attorney’s fees would be structured—and said she would
sign it with those revisions. Mallatt testified that neither Reid nor Sar communicated to
her any additional objections.
Sar testified that she had made additional objections to the agreement during
negotiations that were not incorporated into the agreement. But when pressed by the
court, Sar admitted that the revised agreement incorporated her only contemporaneous
objections and that she did not communicate any further objections during negotiations.
The court then granted REV’s motion to enforce the settlement agreement. At the end of
the hearing, the court addressed Reid’s pending motion to withdraw and asked Sar if
she wished to retain Reid as counsel to finalize the agreement. Sar responded that she
did.
After the hearing, Sar refused to sign the agreement and filed numerous pro se
motions arguing that she never agreed to the terms of the settlement agreement. The
court ordered her to stop filing pro se motions while she was represented by counsel.
REV then moved to dismiss the case with prejudice. The court granted the motion,
ordering both parties to comply with their obligations under the agreement.

-- 2 of 4 --

No. 25-2535 Page 3
Sar, now pro se, appeals. She first argues that the district court erred by
enforcing the settlement agreement because there was no meeting of the minds. We
review the district court’s decision to enforce the settlement agreement for abuse of
discretion, but whether the parties reached a settlement agreement is a question of law
that we review de novo. Beverly v. Abbott Laboratories, 817 F.3d 328, 332–33 (7th Cir.
2016).
The district court correctly determined that the parties reached a settlement
agreement. We apply state contract law to determine whether a settlement agreement
exists. Id. at 333. Indiana law requires a settlement to include, among other things, a
meeting of the minds, which “focuses on each party’s outward manifestation of intent,”
not their subjective intent. Ellison v. Town of Yorktown, 47 N.E.3d 610, 619 (Ind. Ct. App.
2015). Here, both parties expressed intent to accept the revised agreement: After
receiving REV’s draft agreement, Reid explained that Sar would accept it with certain
revisions, and REV incorporated those changes.
Sar emphasizes that she never signed the agreement, but Indiana law does not
require a written and signed settlement agreement, so long as the terms are sufficiently
definite and the parties demonstrate an intent to be bound. Jonas v. State Farm Life Ins.
Co., 52 N.E.3d 861, 868 (Ind. Ct. App. 2016). Here, the written agreement contained
definite terms that were negotiated by the parties, and Sar, through counsel, expressed
her intention to be bound.
Sar contends that there was no meeting of the minds because she objected to
material terms of the agreement. But at the hearing, Sar, Reid, and Mallatt confirmed
that Sar did not communicate any objections during negotiations that were not
incorporated into the agreement. So even if Sar subjectively disagreed with the terms,
her outward manifestation of intent to be bound by them controls.
Sar also appears to argue that her counsel was ineffective during settlement
negotiations. But there is no constitutional right to effective assistance of counsel in a
civil case. Stanciel v. Gramley, 267 F.3d 575, 581 (7th Cir. 2001).
To the extent that Sar takes issue with her attorney’s acceptance of the
agreement, she is bound by it because her attorney had the actual authority to finalize
the agreement. “Actual authority is created by written or spoken words or other
conduct of the principal which, reasonably interpreted, causes the agent to believe that

-- 3 of 4 --

No. 25-2535 Page 4
the principal desires him so to act on the principal's account.” Scott v. Randle, 697 N.E.2d
60, 66 (Ind. Ct. App. 1998). Here, the district court credited Reid’s testimony that when
she explained the terms of and proposed changes to the agreement, Sar said, “[a]s long
as that’s the agreement, we can move forward with a settlement agreement.” Tr. of
Mar. 24, 2025, Hr’g at 11:14–15.
Reid also possessed apparent authority to accept the agreement. Apparent
authority exists “when a party places an agent in the position of sole negotiator on his
behalf” and the third person reasonably believes “that the agent possesses authority to
act for the principal.” Scott, 697 N.E.2d at 67. Sar authorized Reid to negotiate a
settlement on her behalf and was aware of the negotiations. See id.
Next, Sar argues that at the evidentiary hearing the district court improperly
credited Reid’s testimony. But we defer to the district court’s credibility determination
because Sar gives us no compelling reason to overturn the court’s amply supported
decision. See Anderson v. City of Bessemer City, 470 U.S. 564, 575 (1985).
Finally, Sar argues that the district court compelled her to retain Reid as counsel.
She contends that she permitted Reid to continue representing her only because the
court instructed her to do so during the hearing. But the court merely asked Sar if she
wanted to retain Reid as counsel to finalize the agreement, and she said that she did. A
party who wishes to represent herself must “clearly and unequivocally discharge any
lawyer previously retained,” and Sar did not do so. See Tuduj v. Newbold, 958 F.3d 576,
579 (7th Cir. 2020) (citation omitted).
AFFIRMED

-- 4 of 4 --