In Batiste v. Davis, (an unreported 2025 Maryland Appellate Court decision) the appellants (Batiste and Roy, the “Creditors”) claimed Gervonta Davis committed a material breach of contract by failing to pay the full $35,000 due under a 2014 Confidential Settlement Agreement, which had released him from a prior 2013 boxing management contract. The Creditors received only $2,000 by the 2016 payment deadline. They argued this breach triggered a clause allowing reinstatement of the original 2013 contract, entitling them to 15% of Davis’s boxing earnings through 2020.
They sued and obtained a default judgment of $390,000, based on known fight earnings during this so-called “second managerial period.” Davis later settled in 2022, agreeing to pay $468,000, covering the judgment and post-judgment costs. The Creditors accepted the money but didn’t record the judgment as satisfied, and continued seeking discovery, allegedly to enforce additional earnings they believed were still owed under the reinstated contract.
The appellate court rejected the Creditors’ argument, holding:
- The 2014 settlement was the controlling agreement.
- Any breach (e.g., failure to pay $35,000) was remedied by the 2022 settlement, which fully satisfied the 2019 judgment.
- Under Maryland Rule 2-626, once the agreed amount was paid, the judgment was satisfied, and no further discovery could be pursued without a new judgment.
- The Creditors could not seek post-judgment discovery for a “hypothetical” claim.
Although the initial breach of the 2014 agreement was alleged to be material (i.e., nonpayment of $33,000), the court did not disturb that finding. However, it emphasized that even if that breach had reinstated the old contract, the later 2022 Agreement settled the entire dispute, extinguishing any right to enforce prior agreements unless a new judgment was pursued.
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