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Keywords

settlementliabilityappealtrialtestimonysummary judgmentwillleasesustained

depositionappealsummary judgmentwilllease

Related Cases

Harriman v. Maddocks, 518 A.2d 1027

Facts

The case arose from a motor vehicle collision on November 30, 1984, when Harlan M. Maddocks failed to yield at an intersection, resulting in a crash with a dump truck driven by Doyle Harriman. Harriman sustained a hairline fracture of the clavicle and incurred significant medical expenses. Following the accident, the claims adjuster, William Claffy, negotiated a settlement with the Harrimans, which included a $7,500 payment and a signed release form that purported to absolve Maddocks and Allstate from further liability. However, the Harrimans later claimed they were misled about the scope of the release.

The Harrimans' deposition asserts that they signed the release form and cashed the check because Claffy assured them that despite the exculpatory language of both the release and the check, they were releasing only further claims for damage to the truck and that the Harrimans would not be precluded from recovering future medical expenses.

Issue

The main legal issues were whether the release signed by the Harrimans was valid or obtained through fraudulent misrepresentation, and whether the release fully integrated the parties' agreement.

Whether the release was obtained by fraudulent misrepresentations and therefore invalid and whether the release was intended to fully integrate parties' agreement presented genuine issues of material fact precluding summary judgment.

Rule

The court applied the principle that a release can be set aside if it is shown to be the product of fraud, misrepresentation, or overreaching. Additionally, the court noted that parol evidence is admissible to prove fraudulent inducement.

While it is true that a valid release will extinguish a cause of action … the release will nevertheless be set aside if shown to be the product of fraud, misrepresentation, or overreaching.

Analysis

The court found that the conflicting testimonies from the Harrimans and Claffy regarding the intent and understanding of the release created genuine issues of material fact. The Harrimans asserted that they were assured by Claffy that the release only pertained to property damage and would not preclude future medical claims, while Claffy's testimony contradicted this assertion. The court determined that these factual disputes needed to be resolved at trial, rather than through summary judgment.

The specific factual assertions set forth in [the depositions], if believed by the trier of fact, are sufficient to justify setting aside the release on grounds either of misrepresentation or overreaching.

Conclusion

The Supreme Judicial Court vacated the summary judgment in favor of Maddocks and remanded the case for further proceedings, emphasizing that the conflicting evidence warranted a trial to resolve the factual disputes.

Our decision to vacate the Superior Court's grant of summary judgment is required by the particular circumstances of this case.

Who won?

The Harrimans prevailed in the appeal as the court found that there were genuine issues of material fact that precluded summary judgment.

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