Smythe v. Waffle House

In Smythe v. Waffle House, 170 N.C. App. 361, 612 S.E.2d 345, disc. review denied, 360 N.C. 66, 621 S.E.2d 876 (2005), appeal after remand, N.C. App. 643 S.E.2d 407 (2007), a compromise settlement agreement between the parties indicated that the plaintiff, who was not represented by counsel, had not returned to work when she entered into the agreement. However, the settlement agreement contained no mention of the plaintiff's age, educational level, past vocational training, or past work experience, as required under Rule 502(2)(h). The Court concluded that "it was statutorily impermissible for the Commission to approve the settlement agreement without the required biographical and vocational information, and the Commission should have set aside its order of approval." Id. at 366, 612 S.E.2d at 349.