Harrington Is Still Alive

I heard recently, perhaps in court or on one of the family law listserves, that "Harrington is dead."  What is Harrington you ask?  As I previously blogged, Harrington is a case that stands for the proposition that if parties come to an agreement, that agreement can be enforced, even if there is no final written Marital Settlement Agreement.  Those who opined that "Harrington is dead" based this on the Supreme Court's decision in the Willingboro Mall case that I blogged on last year.  In that case, the Supreme Court held that going forward, a settlement that is reached at mediation but not reduced to a signed written agreement will not be enforceable.  But what happens when the settlement was not reached at mediation, but as commonly happens, was reached at the courthouse on the eve of trial?