Only monetary claims may be the subject of a Rule 167 offer. Lauren is seeking the court to impose a constructive trust (an equitable remedy) on 10% of future inspection sales generated by Hartford and State Farm. While this is an equitable remedy, the imposition of the constructive trust will result in monetary damages. The issue is whether this would classify as a monetary claim for rule 167 purposes? Under rule 167.2, “an offer must not include non-monetary claims and other claims to which this rule does not apply.” Secondary sources state that “offer to settle nonmonetary claims must be made separately from a Rule 167 offer.” In Longsdon, the court held that the defendant husband could make a rule 167 offer to settle the wife’s tort
