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West Virginia Supreme Court Upholds Settlement in College Employment Dispute

The West Virginia Supreme Court of Appeals has affirmed lower court decisions upholding a settlement agreement between former Bluefield State College professor Shelia Hallman-Warner and the college's board of governors. Hallman-Warner's petition to invalidate the settlement on fraud grounds was rejected by all three levels of the state court system.

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4 min readcourtlistener
Seal of the West Virginia Supreme Court

Case Information

Case No.:
No. 23-267

Key Takeaways

  • West Virginia Supreme Court affirmed settlement validity between former professor and Bluefield State College
  • Hallman-Warner's fraud claims and petition to invalidate settlement were rejected at all court levels
  • Settlement arose from three-day court-ordered mediation with both parties represented by counsel
  • Supreme Court found no substantial question of law warranting oral argument or full opinion

The West Virginia Supreme Court of Appeals issued a corrected memorandum decision on Jan. 21, 2026, affirming the validity of a settlement agreement between former college professor Shelia Hallman-Warner and Bluefield State College Board of Governors. The court rejected Hallman-Warner's attempts to invalidate the confidential settlement, which arose from her employment at the state institution.

The case, captioned *Hallman-Warner v. Bluefield State College Board of Governors* (W. Va. 2026), represents the final chapter in a multi-year legal dispute that progressed through all three levels of West Virginia's court system. The Supreme Court's decision affirms both a Circuit Court of Kanawha County ruling from July 8, 2022, and a March 6, 2023, decision by the Intermediate Court of Appeals of West Virginia.

According to court documents, Bluefield State College employed Hallman-Warner as a professor before disputes arose during her tenure. The underlying employment-related case led to court-ordered mediation, where both parties were represented by counsel during a three-day process that resulted in confidential settlement terms. The parties subsequently formalized their agreement in writing.

However, months after executing the settlement, Hallman-Warner filed a self-represented petition with the circuit court seeking to invalidate the agreement. The Intermediate Court of Appeals characterized her petition as "difficult to follow" in its March 2023 memorandum decision. Despite the challenging nature of her filing, both Bluefield State College and Hallman-Warner's former counsel responded to her allegations.

Hallman-Warner argued that the settlement agreement should be invalidated on several grounds, including fraud. She also filed additional documents, including what she titled an "Amendment to Filings April 30, 2021 and June 08, 2021 Petition to Invalidate," as she continued to challenge the settlement's validity.

The circuit court ultimately denied her petition to invalidate the settlement agreement in July 2022. Hallman-Warner then appealed to the Intermediate Court of Appeals, which affirmed the lower court's decision in March 2023. Undeterred, she petitioned the state's highest court for review.

In its corrected memorandum decision, the West Virginia Supreme Court of Appeals found no merit in Hallman-Warner's arguments. The court wrote that "upon our review, finding no substantial question of law and no prejudicial error, we determine that oral argument is unnecessary and that a memorandum decision affirming the ICA's memorandum decision is appropriate."

The Supreme Court's decision follows established precedent regarding settlement agreements, which courts generally favor as a means of resolving disputes without lengthy litigation. Settlement agreements are typically binding contracts that courts will enforce unless there are compelling legal grounds for invalidation, such as fraud, duress, or mutual mistake.

The case highlights the difficulty parties face when attempting to invalidate settlement agreements after execution. Courts require clear and convincing evidence of grounds such as fraud, and the fact that both parties were represented by counsel during the mediation process likely strengthened the settlement's validity.

The three-day mediation process that led to the original settlement demonstrates the thorough nature of the negotiations. Court-ordered mediation typically involves neutral mediators who help parties reach mutually acceptable resolutions, and the presence of counsel for both sides ensures that parties understand their rights and obligations.

Hallman-Warner's decision to represent herself in the invalidation proceedings, while not uncommon, may have complicated her ability to present her arguments effectively. The Intermediate Court of Appeals' characterization of her petition as "difficult to follow" suggests potential challenges in articulating her legal theories.

The Supreme Court's use of a memorandum decision, rather than a full opinion, indicates that the justices viewed the case as not presenting novel legal issues requiring extended analysis. Memorandum decisions are typically reserved for cases where the law is well-settled and the outcome is clear based on existing precedent.

The corrected nature of the Supreme Court's decision suggests there may have been minor technical issues with the original filing, though such corrections are routine administrative matters that do not affect the substance of the ruling.

This case serves as a reminder that settlement agreements, particularly those reached through formal mediation with legal representation, carry strong presumptions of validity. Parties seeking to invalidate such agreements face a high burden of proof and must present compelling evidence of legal grounds for invalidation.

For Bluefield State College, the decision provides finality to the employment dispute and confirms the binding nature of the confidential settlement terms. The college can now move forward with certainty that the matter has been conclusively resolved through the state's court system.

The case also demonstrates the effectiveness of West Virginia's three-tier court system in thoroughly reviewing legal disputes, ensuring that all parties receive due process while maintaining the integrity of settlement agreements that help reduce court congestion and provide closure for litigants.

Topics

employment lawsettlement agreement validityfraud allegationsappellate procedure

Original Source: courtlistener

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