"Settlement" was binding after attorney agreed to settle case in court, with City of NY.  The evidence?  Not a transcript, not the client in open court; it was a marking on the "court card" of "settled" made by the clerk. 

This is an expansion of the "settlement in open court" doctrine, which holds that there must be either a writing or an acknowledgement of settlement in open court, on the record.  Here plaintiff wanted to try the case, but was bound by her attorney’s apparent although exceeded authority.

"Plaintiff implicitly ratified the settlement by making no formal objection for nearly seven months after being told about it (Clark v Bristol-Myers Squibb & Co., 306 AD2d 82, 85 [2003]). Furthermore, the requirements of CPLR 2104 were met when, following the conference and counsel’s acceptance of the settlement, the court clerk updated the court card to read "settled before trial" and marked the case "disposed" in the court’s records (Popovic v New York City Health & Hosps. Corp., 180 AD2d 493 [1992]). "