Antal v. Taylor

Citations: 146 Ill. App. 3d 863; 100 Ill. Dec. 327; 1986 Ill. App. LEXIS 2709; 497 N.E.2d 305Docket: No. 4—85—0413

Court: Appellate Court of Illinois; May 21, 1986; Illinois; State Appellate Court

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Doris Antal appeals a dismissal of her personal injury complaint against Mattie L. Taylor, following an accident where Taylor's car collided with the vehicle driven by Antal's then fiancé, Tibor Antal. Taylor counterclaimed against Tibor and moved to dismiss Doris's complaint, citing a general release signed by Doris, which Taylor argued barred her claims. The court considered the legal implications of the release based on pleadings, affidavits, and Doris's deposition. 

The accident occurred on December 23, 1982, resulting in Doris sustaining minor injuries without immediate medical treatment. She continued to work as a laborer, experiencing initial headaches and bruising that subsided. However, after changing her job duties two weeks later, she developed shoulder and neck stiffness, which she initially attributed to overwork. As her condition worsened, she sought medical help and was eventually diagnosed with a ruptured disc, leading to surgery on April 21, 1983, and significant medical expenses and lost wages.

Prior to signing the release for payment of her car repair costs on February 4, 1983, Doris believed it applied solely to her vehicle damage, not to any potential personal injury claims. The release explicitly covered all known and unknown future injuries, which Doris did not intend to include when signing. The facts indicate a potential misunderstanding of the release's scope, particularly regarding her personal injury claims stemming from the accident.

The trial court concluded that the plaintiff did not prove a mutual mistake of fact or fraud regarding her injuries from an accident. It found that both parties were aware of the plaintiff's pain, that she did not seek medical attention prior to signing a release, and that both she and her husband read the release before signing. The court determined that the plaintiff did not exercise reasonable care in understanding her injury, leading to the dismissal of her case. The appeal focuses solely on whether the release should bar the plaintiff's claim, with the plaintiff arguing that the trial court's finding of no mutual mistake contradicted the evidence and that the release imposed an unconscionable hardship. Illinois case law has addressed the validity of releases under claims of mutual mistake of fact, emphasizing that releases may be set aside if they result in gross unfairness when the true extent of injuries is later revealed. The plaintiff bears the burden of proving such a mistake and that her settlement was unconscionable. Evidence showed her medical expenses exceeded $5,000, and she lost five months of work, indicating the settlement of $2,412.29 was grossly inadequate. The trial court acknowledged that both parties were aware of the plaintiff's pain, but it erred by not recognizing that the full extent of her injuries, particularly from a back injury, was unknown at the time of the settlement.

The court determined that the plaintiff did not seek medical attention following the accident and prior to signing the release, nor did she reasonably assess her injury. However, these conclusions were found to contradict the substantial evidence presented. The plaintiff sought treatment as soon as her symptoms appeared and is only required to exercise reasonable diligence in obtaining treatment, not to seek care before symptoms manifest. Under Illinois law, if there is a misunderstanding regarding the extent of known injuries, a release clause covering unforeseen consequences may be set aside. The plaintiff was compensated solely for vehicle repairs in exchange for the release, highlighting a clear mutual mistake of fact. Thus, the release does not prevent the plaintiff from pursuing her personal injury claim. The trial court's dismissal was reversed and the case remanded for further proceedings. WOMBACHER and HEIPLE, JJ. concur.