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Lanni v. Smith
Citations: 89 A.D.2d 782; 453 N.Y.S.2d 497; 1982 N.Y. App. Div. LEXIS 17895
Court: Appellate Division of the Supreme Court of the State of New York; July 9, 1982; New York; State Appellate Court
Order affirmed with costs. General Motors Corporation (GMC) appeals the denial of its motion to dismiss a third-party complaint. The critical issue is whether a release signed by Gregg Smith, the defendant and third-party plaintiff, on December 19, 1979, was limited to his personal injury claims from a June 8, 1977, automobile accident or if it also included claims for contribution regarding injuries to his passenger, Patricia Lanni. Smith settled for $10,000 and provided a release, which was prepared by his attorney and contained broad language but specifically referenced only his personal injuries in the typewritten portion. A subsequent release from Smith's insurance carrier mirrored this language, addressing only Smith’s injuries and property damage. Legal precedent indicates that general release language can be restricted by specific recitals, meaning the release cannot be interpreted to cover other claims if it explicitly limits itself to particular injuries. In this case, the typewritten language indicating the scope of the release suggests it was intended solely to resolve Smith’s claims, with no implication of covering additional claims related to Lanni’s injuries. The release in question does not include language indicating that it covers all claims related to the accident. Previous cases, such as Benzinger v Wochensky and Dury v Dunadee, demonstrate that specific wording is necessary for a release to be interpreted broadly. The two documents executed by Smith and Hartford only reference personal injuries and property damage suffered by Smith, lacking comprehensive coverage. The case of Mt. Read Term. v LeChase Constr. Corp. is distinguishable because it involved a general release resulting from extensive negotiations in a complex dispute, where the intent to settle various claims was supported by testimony and specific exceptions. In contrast, the current case focuses on the legal interpretation of the release's wording, specifically whether it was meant to release all claims from the accident or solely those related to Smith's injuries. The situation is also unlike Mangini v McClurg, where the issue revolved around the effect of a general release due to mutual mistake regarding injuries. Here, there are no factual disputes, and the interpretation of the contract is purely a legal question, negating any burden of proof concerns. The appeal arises from an order of the Supreme Court, Genesee County, concerning a third-party action for contribution.