ATTORNEY FOR APPELLANTS            ATTORNEYS FOR APPELLEE
Stephen Gerald Gray                    Bryce H. Bennett, Jr.
Indianapolis, Indiana                    Michael Patrick Dugan
                            Riley Bennett & Egloff
                    Indianapolis, Indiana

A.D.R. 2.12 (1995). Evidence Rule 408 contains a parallel provision.
    We note that, in general, settlement agreements need not be in writing to be enforceable. Ind. Farmers Mut. Ins. Co. v. Walters, 221 Ind. 642, 646, 50 N.E.2d 868, 869 (1943); Klebes v. Forest Lake Corp., 607 N.E.2d 978, 982 (Ind. Ct. App. 1993). However, when a settlement agreement is reached in mediation, the mediation rules required that "it shall be reduced to writing and signed." A.D.R. 2.7(E)(2). See footnote In Silkey v. Investors Diversified Serv., Inc., 690 N.E.2d 329 (Ind. Ct. App. 1997), the Court of Appeals confronted the issue of "what effect, if any, should be given to the oral agreement reached by the parties at the conclusion of a mediation." Id. at 331-32. Unlike the present case, the parties in Silkey agreed that an agreement was reached, and the claim presented was whether the agreement was enforceable even though it was not signed. Noting that the terms of the agreement were not in dispute, the Court of Appeals held that the trial court acted properly in ordering the parties to reduce their agreement to writing and to file it with the court. Id. at 334. The Silkey court did not address the admissibility of evidence to establish the existence and terms of an alleged oral mediation settlement agreement.
    Because of the nature of the mediation process and its significant and increasing role, considerable attention has been given to whether claims of oral mediation settlement agreements should be enforceable. We note that the March 2000 discussion draft of a proposed Uniform Mediation Act under consideration by the National Conference of Commissioners on Uniform State Laws provides that "a record of an agreement between two or more disputants" shall not be protected by privilege or prohibition against disclosure, Section 8(a)(1), and the Reporter's Notes provide the following thoughtful explanation:
This exception is noteworthy only for what is not included: oral agreements. The disadvantage of exempting oral settlements is that nearly everything said during a mediation session could bear on either whether the disputants came to an agreement or the content of the agreement. In other words, an exception for oral agreements has the potential to swallow the rule. As a result, mediation participants might be less candid, not knowing whether a controversy later would erupt over an oral agreement. Unfortunately, excluding evidence of oral settlements reached during a mediation session would operate to the disadvantage of a less legally-sophisticated disputant who is accustomed to the enforcement of oral settlements reached in negotiations. Such a person might also mistakenly assume the admissibility of evidence of oral settlements reached in mediation as well. However, because the majority of courts and statutes limit the confidentiality exception to signed written agreements, one would expect that mediators and others will soon incorporate knowledge of a writing requirement into their practices. See Ryan v. Garcia , 27 Cal. App.4th 1006 (1994) (privilege statute precluded evidence of oral agreement); Hudson v. Hudson , 600 So.2d 7 (Fla. App. 1992) (privilege statute precluded evidence of oral settlement); Cohen v. Cohen , 609 So.2d 783 (Fla. App. 1992) (same); Ohio Rev. Code § 2317.02-03 (Baldwin 1998).

Nat'l Conf. of Comm'rs on Unif. State Laws, Uniform Mediation Act, Draft Report, Section 8, Reporter's Note 2, Subsection 8(a)(1), Record of an Agreement (Mar. 2000) <http://www.law.upenn.edu/bll/ulc/ulc_frame.htm>.
    We agree with this approach. Notwithstanding the importance of ensuring the enforceability of agreements that result from mediation, other goals are also important, including: facilitating agreements that result from mutual assent, achieving complete resolution of disputes, and producing clear understandings that the parties are less likely to dispute or challenge. These objectives are fostered by disfavoring oral agreements, about which the parties are more likely to have misunderstandings and disagreements. Requiring written agreements, signed by the parties, is more likely to maintain mediation as a viable avenue for clear and enduring dispute resolution rather than one leading to further uncertainty and conflict. Once the full assent of the parties is memorialized in a signed written agreement, the important goal of enforceability is achieved. We decline to find that the enforcement of oral mediation agreements is a sufficient ground to satisfy the "offered for another purpose" exception to the confidentiality rule and Evidence Rule 408.
    We therefore hold that the mediation confidentiality provisions of our A.D.R. Rules See footnote extend to and include oral settlement agreements undertaken or reached in mediation. Until reduced to writing and signed by the parties, mediation settlement agreements must be considered as compromise settlement negotiations under the applicable A.D.R. Rules and Evidence Rule 408. See footnote
    Having previously granted transfer, thereby vacating the opinion of the Court of Appeals, we now reverse the judgment of the trial court and remand this cause for a jury trial.

    SHEPARD, C.J., SULLIVAN, BOEHM, and RUCKER, JJ., concur.