Sanchez v. Prudential Pizza, Inc.

Dist. Ct. erred in denying plaintiff’s request for attorney fees and costs after finding that Rule 68 settlement offer by defendant to which plaintiff had previously agreed in instant Title VII action were already included in said offer. Plaintiff was entitled to said fees and costs since: (1) plaintiff was prevailing party in her Title VII action; (2) instant Rule 68 offer of $30,000 in exchange for “all of plaintiff’s claims for relief” was ambiguous with respect to whether said “claims” included attorney fees and costs; and (3) any ambiguity required finding that fees and costs were not included in settlement offer. Fact that plaintiff listed attorney fees when she set forth her demands for relief in her amended complaint did not require different result.