OBED COLON
v.
CITY OF RIVIERA BEACH
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An unambiguous release that expressly releases a defendant from discrimination claims is binding and bars a subsequent suit under the Florida Civil Rights Act of 1992, with the release's interpretation governed by state contract law principles.
[1] A release signed in connection with a worker's compensation claim settlement, which expressly releases a party from claims alleging discrimination, is governed by state c…
[2] The interpretation of a release agreement is a matter of state law, even when the underlying claim is based on a statute patterned after federal law.
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Join FLexlaw to unlock all legal intelligence“Because a release is a contract, it must be interpreted according to principles of contract law.”
Court's explanation of the governing standard for interpreting releases
Colon signed a release in connection with a worker's compensation settlement that expressly released the City of Riviera Beach from any claim alleging…
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PER CURIAM. We affirm the final summary judgment entered in favor of appellee City of Riviera Beach in appellant’s suit against the City for violations of his rights under the Florida Civil Rights Act of 1992 (“FCRA”). The trial court determined that a release signed by appellant in connection with a settlement of a worker’s compensation claim which expressly released the City from any claim alleging discrimination was “plain, unambiguous and binding under state law.” While appellant argues that we should apply federal law to determine whether the release bars his claim, we disagree. Although a Florida statute, like FCRA, is to be given the same construction as federal courts would give the federal act after which FCRA was patterned, e.g., Carsillo v. City of Lake Worth, 995 So. 2d 1118, 1119 (Fla. 4th DCA 2008), the issue in this case is the interpretation of the release, which is governed by state law. See Home Devco/Tivoli Isles LLC v. Silver, 26 So. 3d 718, 720 (Fla. 4th DCA 2010); see also Liberty Mut. Ins. Co. v. Wolfson, 299 So. 3d 28, 32 (Fla. 4th DCA 2020) (explaining that “[b]ecause a release is a contract, it must be interpreted according to principles of contract law.” (quoting Berrios v. Orlando Reg’l Healthcare Sys., 100 So.
2
3d 128, 130 (Fla. 5th DCA 2012))). Under Florida law, the trial court did not err in entering summary judgment based on the unambiguous release. See Caballero v. Phoenix Am. Holdings, Inc., 79 So. 3d 106, 107 (Fla. 3d DCA 2012); AXA Equitable Life Ins. Co. v. Gelpi, 12 So. 3d 783, 786 (Fla. 3d DCA 2009). Affirmed. WARNER, DAMOORGIAN and FORST, JJ., concur.
* * * Not final until disposition of timely filed motion for rehearing.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
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Obed Colon v. City of Riviera Beach, 299 So. 3d 28 (Fla. 4th DCA 2021)…18, 1119 (Fla. 4th DCA 2008), the issue in this case is the interpretation of the release, which is governed by state law. See Home Devco/Tivoli Isles LLC v. Silver, 26 So. 3d 718, 720 (Fla. 4th DCA 2010); see also Liberty Mut. Ins. Co. v. Wolfson, 299 So. 3d 28, 32 (Fla. 4th DCA 2020) (explaining that “[b]ecause a release is a contract, it must be interpreted according to principles of contract law.” (quoting Berrios v. Orlando Reg’l Healthcare Sys., 100 So. 3d 128, 130 (Fla. 5th DCA 2012))). Under Florid…
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Muentes v. Bruce Rosenwater & Assocs., P.A. (Fla. 4th DCA 2023)…illed on an hourly basis for work performed.” (emphasis added). Use of the word term “[w]hen” indicates a moment in time, meaning Clients would begin being billed hourly when the initial retainer is depleted. See Liberty Mut. Ins. Co. v. Wolfson, 299 So. 3d 28, 35 (Fla. 4th DCA 2020) (under the doctrine of noscitur a sociis, “a word is known by the company it keeps” and should be interpreted with reference to the other words in the context that those words appear). Additionally, the agreement does not ex…
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Muentes v. Bruce Rosenwater & Assocs., P.A. (Fla. 4th DCA 2023)…illed on an hourly basis for work performed.” (emphasis added). Use of the word term “[w]hen” indicates a moment in time, meaning Clients would begin being billed hourly when the initial retainer is depleted. See Liberty Mut. Ins. Co. v. Wolfson, 299 So. 3d 28, 35 (Fla. 4th DCA 2020) (under the doctrine of noscitur a sociis, “a word is known by the company it keeps” and should be interpreted with reference to the other words in the context that those words appear). Additionally, the agreement does not ex…
Authorities Cited
- Carsillo v. City OF Lake Worth, 995 So. 2d 1118 (Fla. 4th DCA 2008)
- AXA Equitable Life Ins. Co. v. Gelpi, 12 So. 3d 783 (Fla. 3d DCA 2009)
- Home Devco/Tivoli Isles LLC v. Silver, 26 So. 3d 718 (Fla. 4th DCA 2010)
- Obed Colon v. City of Riviera Beach, 299 So. 3d 28 (Fla. 4th DCA 2021)
- Caballero v. Phoenix Am. Holdings, Inc., 79 So. 3d 106 (Fla. 3d DCA 2012)