U.S. Court of Appeals for the Second Circuit
Smith v. Home Depot U.S.A., Inc.
September 4, 2026
Summary
The Second Circuit affirmed the district court's order enforcing an oral settlement agreement between Duane Smith and Home Depot and third‑party defendants. The court held that Smith's former attorney possessed actual authority to bind him to the settlement and that the oral agreement was enforceable under the Winston factors.