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Structural Processing Corp. v. Farboil Co.

Citations: 234 A.D.2d 284; 650 N.Y.S.2d 769; 1996 N.Y. App. Div. LEXIS 12774

Court: Appellate Division of the Supreme Court of the State of New York; December 1, 1996; New York; State Appellate Court

Narrative Opinion Summary

In an appeal regarding a breach of contract, the defendant contested a Supreme Court order from December 4, 1995, which denied its motion for summary judgment to dismiss the complaint. The appellate court affirmed the order with costs. The determination of a general release's meaning and scope is contingent on the specific controversy being settled and the intent behind the release. A release cannot be interpreted to cover issues that the parties did not intend to resolve. The plaintiff argued that the release was related to a prior settlement concerning construction projects at Trump Plaza and Carlyle Towers. The defendant did not prove that this release intended to preclude recovery related to a different construction project involving a McDonald's restaurant. Several cases were cited to support this conclusion, emphasizing the requirement for clear intent in the drafting of releases. Judges Bracken, Copertino, Joy, Florio, and McGinity concurred with the decision.

Legal Issues Addressed

Burden of Proof in General Release Disputes

Application: The defendant failed to prove that the general release was intended to preclude recovery for a construction project unrelated to the ones mentioned in the release.

Reasoning: The defendant did not prove that this release intended to preclude recovery related to a different construction project involving a McDonald's restaurant.

Interpretation of General Release in Contract Disputes

Application: The appellate court determined that the scope of a general release must be evaluated based on the specific controversy it addresses and the intent of the parties involved.

Reasoning: The determination of a general release's meaning and scope is contingent on the specific controversy being settled and the intent behind the release.

Limitations of a General Release

Application: The court affirmed that a release cannot cover issues that the parties did not intend to resolve, highlighting the necessity of clear intent in the drafting of releases.

Reasoning: A release cannot be interpreted to cover issues that the parties did not intend to resolve.