Gibli v. Benderson Development Company, 92 N.Y.2d 1017 (1998)

A clear and unambiguous release signed by a party is a binding “jural act” and will be enforced absent a showing of fraud, duress, or some other valid legal reason to invalidate the agreement.

Summary

A drywall installer, Gibli, injured his knee at work and later signed a “release of all claims” with Benderson Development’s insurance carrier for $3,000, releasing Benderson and Northeast Mechanical from liability. Gibli then sued for negligence and Labor Law violations, arguing the release was fraudulent. The Supreme Court found factual questions regarding the release’s validity. The Appellate Division reversed, holding the release valid. The Court of Appeals affirmed, emphasizing that a clear, unambiguous release is binding unless fraud is proven, which Gibli failed to demonstrate.

Facts

Plaintiff Gibli, a drywall installer, sustained a knee injury while on stilts at a construction site.
Ten months post-injury, Gibli signed a document titled “release of all claims” presented by Benderson Development’s insurance representative.
The release explicitly discharged Benderson and Northeast Mechanical from “any and every claim…especially the liability arising from” Gibli’s accident, for $3,000.
The release contained the warning: “you are making a final settlement, this is a RELEASE. READ CAREFULLY BEFORE SIGNING.”

Procedural History

Gibli sued Benderson and Northeast Mechanical, alleging negligence and Labor Law violations, despite having signed the release.
Defendants moved to dismiss the complaint under CPLR 3211, based on the signed release.
Gibli opposed, claiming fraud in obtaining the release, and cross-moved for summary judgment on liability.
Supreme Court denied both defendants’ motions to dismiss and Gibli’s cross-motion for summary judgment, finding questions of fact about the release’s validity.
The Appellate Division reversed, finding the release valid and binding, thus dismissing Gibli’s claims.
Gibli appealed to the New York Court of Appeals.

Issue(s)

Whether a clear and unambiguous release, signed by the plaintiff, should be enforced to bar the plaintiff’s subsequent claims against the defendant, absent sufficient evidence of fraud or other grounds for invalidating the release.

Holding

Yes, because the plaintiff failed to raise a triable issue of fact regarding the validity of the release, and public policy favors the enforcement of settlements.

Court’s Reasoning

The Court of Appeals emphasized the principle that a clearly worded and unambiguous release constitutes a binding