Settlement Agreements — Affidavit of No Known Insurance Did Not Satisfy Offer’s Required Assurance

Glenwood Motel Enterprise, Inc. v. Martin, No. A26A1588, 2026 WL 2858301, __ S.E.2d __ (Ga. Ct. App. Sept. 23, 2026). The court (Gobeil, J.; Pipkin, J., concurs; Dillard, P.J., concurs fully and specially) affirms denial of a motion to enforce a settlement in a hotel assault case. Acceptance required an affidavit affirmatively stating that no additional liability coverage existed. The defendant instead supplied an affidavit stating that its owner was unaware of other coverage. Id. at **1–2. The court held that this qualified assurance did not strictly comply with an express condition of acceptance, so no enforceable settlement formed despite timely payment of the offered amount. Id. at **2–3. The special concurrence emphasized that the decision applies general contract principles; OCGA § 9-11-67.1’s distinct motor-vehicle settlement rules did not govern this claim. Id. at *4.