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Keywords

contractsettlementappealwilllease
contractappealtrialsummary judgmentwilllease

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Williams v. Glash, 789 S.W.2d 261

Facts

Margaret Williams was a passenger in her family car when it was rear-ended by a vehicle driven by Stephen Glash. At the time of the accident, there were no visible injuries, and Williams was advised by State Farm, Glash's insurer, to submit a claim for property damage. She completed a claim form indicating no injuries and received a check for the estimated repair costs, which included language releasing any claims for bodily injury. Later, Williams was diagnosed with temporomandibular joint syndrome (TMJ) related to the accident, prompting her to seek to invalidate the release.

Williams was later diagnosed as having temporomandibular joint syndrome ('TMJ'), causing head and neck pain, as a result of the accident.

Issue

Whether the execution of the release for personal injuries bars a subsequent suit for an injury that was unknown at the time of signing.

The question presented is whether execution of the release for personal injuries in this cause bars a subsequent suit for an injury unknown at the time of signing.

Rule

Under Texas law, a release is a contract that can be avoided on grounds such as mutual mistake, where both parties were mistaken about a material fact at the time of the contract's execution.

Under Texas law, a release is a contract and is subject to avoidance, on grounds such as fraud or mistake, just like any other contract.

Analysis

The court analyzed whether State Farm met its burden of proving that no genuine issue of material fact existed regarding the release. It found that Williams had no knowledge of her TMJ injury when she signed the release and had not negotiated for a personal injury settlement. The evidence indicated that the release language was not discussed, and the insurer's coding on the check suggested it was solely for property damage. Thus, the court determined that there was a genuine issue of fact regarding the parties' intent concerning the release.

Summary judgment evidence manifesting Williams' objective intent shows that she had no knowledge of the TMJ injury at the time of signing the release.

Conclusion

The Supreme Court of Texas reversed the judgment of the court of appeals and remanded the case for further proceedings, allowing the possibility of avoiding the release based on mutual mistake.

We reverse the judgment of the court of appeals and remand this cause to the trial court for further proceedings.

Who won?

The prevailing party was Margaret Williams, as the Supreme Court ruled in her favor, allowing her to pursue her claim for personal injuries.

Petitioners seek to avoid the effect of the release, imploring this court to follow the 'modern trend' of setting aside releases when the injury later sued for was unknown at the time of signing.

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