Blas v. Cruz

In Blas v. Cruz, 2009 Guam 12, the trial court found that the parties in a divorce action had entered into a settlement agreement. Id. 7. On appeal, the wife argued that the trial court erred when it considered evidence of settlement negotiations for the purpose of determining whether the parties entered into a settlement agreement. Id. 12. The wife argued that consideration of the evidence violated GRE 408, which bars evidence of conduct or statements made in attempting to compromise a claim. Id. 13. The Court found that GRE 408 "bars compromise evidence only when offered as evidence of 'validity,' 'invalidity,' or 'amount' of the disputed claim." Id. 14. Evidence related to a settlement agreement is admissible where it is not offered to prove liability but rather to prove the terms of the settlement agreement or to prove the fact of settlement. Id. 14-15.