In the context of summary proceedings, as with other types of litigation, parties and the courts often prefer that disputes be resolved by consensual agreement. Settlements offer the parties the benefit of finality, and avoid the costs and risks involved in litigating a matter to a final conclusion. Settlements are encouraged by the courts, and it has long been the law that stipulations of settlement are “not lightly cast aside.” Hallock v. State of New York, 64 N.Y.2d 224, 230 (1984). Such is particularly so in the case of “open court” stipulations “where strict enforcement not only serves the interest of efficient dispute resolution but is also essential to the management of court calendars and the integrity of the litigation process.” 1420 Concourse Corp. v. Cruz, 135 A.D.2d 371, 372 (1st Dept. 1987).

Nevertheless, there are limited instances where stipulations of settlement are cast aside, and do not achieve the goal of finality which the parties presumably had intended to achieve by settling their dispute. This is particularly so in the context of pro se litigants, who are generally in a better position to try to avoid the consequences of a stipulation of settlement.