Trace Elements, Inc. v. Nadja MacKensen

Summary

The court held that a joint proposal for settlement must apportion the amount and terms attributable to each party, even when the proposal concerns a unified, single claim for undifferentiated damages. Because the proposal from the two plaintiffs offered only a lump sum without individual allocations, it was invalid under the governing rule and could not support an attorney-fee award. The court therefore enforced the rule strictly and directed further proceedings consistent with its decision.