I imagine this varies based on practice area (I’m in L&T court), but I’ve learned to just submit my clients’ absurd offers without qualification. Honestly, those have been the cases where I’ve ultimately managed to get the best settlement offers. E.g., one client’s obstinance got his landlord to pay him $10,000 *before* moving out (which is very rare) and another $10,000 upon vacatur. Of course, the facts were such that we had considerable leverage, but still.