WHITE PLAINS, NY (April 14, 2026) — In a major development in the high-profile wrongful death lawsuit stemming from the fatal police shooting of Jarrel Garris on July 3, 2023, Westchester County Supreme Court Justice Lewis J. Lubell has ruled that the $300,000 settlement agreement reached at mediation is fully enforceable.
In a Decision & Order dated April 6, 2026 and filed April 7, 2026, Justice Lubell granted the City of New Rochelle and Det. Steven Conn’s Order to Show Cause to enforce the settlement. The court rejected attempts by Estate Administrator Raymond Fowler to back out of the deal and transferred the entire matter to Surrogate’s Court for final approval of the compromise on behalf of the infant beneficiary, allocation of the settlement proceeds, and resolution of the dispute over attorney’s fees.
According to the decision, the parties reached the mediated settlement on March 27, 2025 at National Arbitration and Mediation. The agreement provided $200,000 to the Estate of Jarrel Garris, with $50,000 each to Decedent’s father, Raymond Fowler, and mother, Janet Garris. The only contingency was formal approval by the New Rochelle City Council, which occurred on April 15, 2025. Janet Garris signed a formal Settlement, Withdrawal, Release and Waiver Agreement on August 11, 2025.
Fowler served notice on August 13, 2025 that he was withdrawing from the settlement. Plaintiffs’ counsel subsequently filed a motion to compromise the claim on behalf of the non-party infant Jaremiah Jarrel Garris (Decedent’s son). After multiple court conferences — during which Fowler appeared without counsel on several occasions and ultimately terminated his attorneys’ representation — the court held that the mediation agreement is binding under CPLR 2104.
Justice Lubell wrote that the agreement was signed by counsel for all parties and the mediator, and that Fowler had authorized his counsel to sign and had remotely participated in the mediation. Citing Amerally v Liberty King Produce, Inc. (170 AD3d 637 [2d Dept 2019]), the court found that even apparent authority would suffice and that stipulations of settlement are “favored by the courts and not lightly cast aside.” The decision notes that plaintiffs’ counsel, in their own submission, stated there was “no principled basis” upon which they could oppose enforcement as officers of the court.
The court further held that Fowler cannot appear pro se on behalf of the estate because Decedent’s son is a beneficiary, citing Martins v Liu (216 AD3d 762 [2d Dept 2023]). An administrator may only appear pro se if he or she is the sole beneficiary with no creditors.
“Since there was no showing of a basis on which to invalidate the settlement agreement, … [this Court must] enforce the settlement agreement,” Justice Lubell ruled, citing Kistoo v Spence (241 AD3d 1536 [2d Dept 2025]).
The matter has now been transferred to Surrogate’s Court pursuant to CPLR 325(e). That court will handle the pending infant compromise application, determine the final allocation of the settlement funds, and resolve the dispute between Fowler and former plaintiffs’ counsel regarding attorney’s fees. The Supreme Court and Surrogate’s Court retain concurrent jurisdiction over estate matters, but the decision notes that litigation involving estate funds is preferably conducted in Surrogate’s Court.
Background and Prior Coverage
The underlying lawsuit was filed on September 29, 2024, alleging negligence by the City of New Rochelle and Det. Conn in connection with the shooting that led to Garris’s death on or about July 7, 2023. Fowler was appointed administrator of the estate in January 2025.
This latest ruling comes after months of procedural wrangling, including:
- An August 15, 2025 filing showing the proposed allocation with $200,000 going to the Garris son
- An October 2025 decision initially rejecting settlement approval
- Fowler’s January 2026 challenge to enforcement
- Status conferences in January and March 2026 at which Fowler appeared without counsel
The April 6, 2026 decision effectively ends the fight in Supreme Court over whether the settlement can be enforced and shifts the remaining issues — primarily the protection of the infant beneficiary’s interests and the fee dispute — to Surrogate’s Court.
Talk of the Sound will continue to monitor proceedings in Surrogate’s Court and provide updates as they become available.
Related Stories:
- Recent Court Filings Show $200,000 of New Rochelle Settlement Goes to Garris Son (8/15/2025)
- Court Rejects Settlement Approval in New Rochelle Police Shooting of Jerrel Garris (10/20/2025)
- Estate Administrator Challenges Settlement Enforcement in Jarrel Garris Wrongful Death Lawsuit (1/8/2026)
- Garris Wrongful Death Lawsuit Remains Unresolved as Settlement Dispute Heads to March Court Date (1/29/2026)
- New Rochelle Civil Case Filed by Jarrel Garris Estate Against City Advances With Status Conference (3/26/2026)
Note: The court documents consistently spell the decedent’s first name as “Jarrel.” Some earlier coverage used the variant “Jerrel.”
This article was prepared with the assistance of AI tools under the direction and editing of Robert Cox.
Have information about this story? Email robertcox@talkofthesound.com (preferred) or contact via WhatsApp: +353 089 972 0669.
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