Madrigal v. Hyundai Motor America (2023)

Holding that: (1) collateral order doctrine permitted review of cost-and-fee order; (2) as a matter of first impression, term “judgment” in penalty provision of offer-to-compromise statute was not limited to judgment following trial; (3) as a matter of first impression, terms of settlement agreement supported treating stipulated settlement as “judgment” for purposes of offer-to-compromise statute; (4) as a matter of first impression, application of penalty provision to settlement at hand would serve provision's purposes; (5) merger doctrine did not nullify offer to compromise; and (6) manufacturer's entry into settlement did not revoke offer to compromise under “inconsistent action” rule.