Recently, a state appellate court issued a written opinion in a personal injury case discussing an interesting issue that will occasionally come up in Maryland truck accident cases. Specifically, the case dealt with a settlement agreement that was executed between the plaintiff and several potentially liable parties, whereby the plaintiff accepted compensation in exchange for an agreement to excuse the parties from liability.
The question the court had to answer was whether the broad language of that agreement resulted in the remaining potentially liable parties being excused from liability as well. In so doing, the court took the rare step to consider extrinsic evidence that was not contained in the settlement agreement to determine the intent of the parties.
The Facts of the Case
The plaintiff was injured in an accident involving a sandwich delivery truck. Within two weeks of the accident, the plaintiff entered into a settlement agreement with the vehicle’s owner and the owner’s insurance company. That agreement provided that the plaintiff would receive $25,000, the policy maximum, and in exchange would “release, acquit and forever discharge the said payor(s), their agents and employees, and all other persons, firms or corporations who are or might be liable” for injuries resulting from the accident.
Prior to entering into the settlement agreement, the plaintiff filed a personal injury lawsuit against the driver of the vehicle, the restaurant, and the restaurant’s insurance company. Before the case against these defendants went to trial, the defendants filed a motion to dismiss arguing that the broad language of the settlement agreement excused not just the parties named in the agreement, but also the remaining defendants.
The Court’s Analysis
The court began by explaining that, as a general rule, courts will only look to the text contained in an agreement when interpreting that agreement. However, the court went on to explain that in some unique situations, courts can consider extrinsic evidence that is not contained in the contract.
Here, the court acknowledged that the plain language of the settlement agreement released “all other person…who might be liable for the plaintiff’s injuries.” Thus, on its face, this language seemed to excuse the named defendants. However, the court explained that when there is “substantial evidence of mistaken intent,” extrinsic evidence may be admissible to determine what the parties were thinking when entering into the agreement.
Here, because the settlement agreement was signed just after the case was filed against the named defendants and did not include the named defendants in the agreement, the court held that it would be appropriate to consider extrinsic evidence of the parties’ intent. The court also noted that the parties involved in the settlement agreement were never named in any lawsuit filed by the plaintiff.
Importantly, the court expressed no opinion as to whether the evidence establishes mistaken intent outside of the summary judgment context. Thus, the plaintiff’s case, including the issue of whether the settlement agreement excused the named defendants, will proceed to trial so that it can be resolved by a jury.
Have You Been Injured in a Maryland Truck Accident?
If you or a loved one has recently been injured in a Maryland semi-truck accident, or any other accident involving a commercial vehicle, you may be entitled to monetary compensation. These cases often present unique issues in determining which parties should be named as defendants, and under what theory of liability. The dedicated Maryland truck accident lawyers at the law firm of Lebowitz & Mzhen, LLC have extensive experience handling Maryland truck accidents, including those involving multiple drivers and defendants. To learn more, call 410-654-3600 to schedule a free consultation today.
More Blog Posts:
Maryland Roadside Truck Accidents, Maryland Trucking Accident Lawyer Blog, published August 29, 2018.
The Dangers of Improperly Maintained Tires on Maryland Semi-Trucks, Maryland Trucking Accident Lawyer Blog, published September 5, 2018.