Slater v. United States Steel Corporation
MEMORANDUM OPINION - Ms. Slater does not cast any doubt on the unambiguous meaning of full general release of all claims to which she and her counsel agreed and she does not offer any compelling reason for why the court should disregard the phrases p lain meaning. So, by separate order, the court will DENY Ms. Slaters Motion to Enforce a Settlement of the Claims before the Court/Motion to Set Case for Trial and ORDER Ms. Slater to execute the full general release of all claims proffered by U.S. Steel and reprinted on page two of Ms. Slaters motion on or before January 22, 2019. Signed by Chief Judge Karon O Bowdre on 1/7/2019. (KEK)
2019 Jan-07 PM 03:08
U.S. DISTRICT COURT
N.D. OF ALABAMA
UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ALABAMA
UNITED STATES STEEL
CIVIL ACTION NO.
This matter comes before the court on Plaintiff Sandra Slater’s “Motion to
Enforce a Settlement of the Claims before the Court/Motion to Set Case for Trial.”
(Doc. 109). In settling this case, Ms. Slater agreed to “execute a full general
release of all claims,” but in her motion, Ms. Slater asks the court to let her not
“execute a full general release of all claims.” For the following reasons, the court
will DENY Ms. Slater’s motion and ORDER her to comply with the unambiguous
terms of the settlement agreement and execute a full general release of all claims.
On October 16, 2018, the parties mediated this dispute before Magistrate
Judge England and agreed to settle. Both parties were represented by counsel at
The parties and their counsel signed a Memorandum of Understanding that
stated the terms of the parties’ settlement agreement. (Doc. 113). According to
Ms. Slater, Judge England drafted the Memorandum of Understanding. The
Memorandum of Understanding provides that Ms. Slater “will execute a full
general release of all claims.”
Defendant United States Steel Corporation provided a release for Ms. Slater
to execute. The release states, in part, “Slater hereby RELEASES AND WAIVES
all claims, actions, damages, and causes of action of any type . . . which concern,
or arise out of: (a) her claims asserted in the Action and/or (b) any matter or event
that has occurred between USS and Slater at any time up to the date of this
Settlement Agreement.” (Doc. 109 at 2).
Ms. Slater refuses to execute this release because, according to Ms. Slater,
when she agreed to “execute a full general release of all claims,” she agreed to
release only those claims that she brought in this case. She moves the court to
enforce the settlement agreement, but require her to execute a release of only the
claims that she brought in this case, or, in the alternative, set this case for trial.
(Doc. 109 at 5).
U.S. Steel responded to Ms. Slater’s motion and asserted that “full general
release of all claims” has an unambiguous meaning under Alabama law: a full
release of all claims, not just the specific claims that Ms. Slater brought in this
lawsuit. Accordingly, U.S. Steel asks the court to enforce the settlement
agreement and order Ms. Slater to execute a full general release of all claims.
(Doc. 110 at 5).
The parties do not dispute that they agreed to settle this case, that the
Memorandum of Understanding constitutes their settlement agreement, and that
the Memorandum of Understanding is a valid contract. But they vigorously
dispute the meaning of the phrase “full general release of all claims” in the
contract. For the following reasons, the court will resolve this dispute in favor of
the unambiguous meaning of “full general release of all claims” and order Ms.
Slater to comply with the terms of the settlement to which she agreed and execute a
full general release of all claims, not just the claims she brought in this lawsuit.
Alabama law “requires a court to enforce an unambiguous, lawful contract,
as it is written.” Ex parte Dan Tucker Auto Sales, Inc., 718 So. 2d 33, 35 (Ala.
1998). And when interpreting a contract, “a court should give the terms of the
agreement their clear and plain meaning . . . . Words used in a contract will be
given their ordinary, plain, or natural meaning where nothing appears to show they
were used in a different sense or that they have a technical meaning.” Id. at 36.
Here, the phrase at issue—“full general release of all claims”—has a plain
and ordinary meaning: it means a release of all claims, not just the specific claims
that may be at issue. See Reg’l Health Servs., Inc. v. Hale Cty. Hosp. Bd., 565 So.
2d 109, 114 (Ala. 1990) (“With a general release, the parties obviously intend to
release all claims . . . .”). Likewise, Black’s Law Dictionary defines “general
release” as “[a] broad release of legal claims that is not limited to a particular claim
or set of claims, such as those at issue in a pending or contemplated lawsuit, but
instead covers any actual or potential claim by the releasing party against the
released party based on any transaction or occurrence before the release.” Black’s
Law Dictionary (10th ed. 2014). Thus, by agreeing to “execute a full general
release of all claims,” Ms. Slater agreed to release all claims, not just the claims
brought in this case.
Ms. Slater essentially asks the court to interpret “full general release of all
claims” as a “limited release of specific claims.” But, if a party intends to limit the
scope of claims they will release, Alabama law requires that party to specifically
do so in the contract. See Cavender v. State Mut. Ins. Co., 748 So. 2d 863, 868
(Ala. 1999) (“When the language of a release specifically limits the scope of the
release, the release will not bar claims outside the scope of the release.”); Wayne J.
Griffin Elec., Inc. v. Dunn Const. Co., 622 So. 2d 314, 317 (Ala. 1993) (“If the
parties had intended to limit the releases, they could have specifically done so.”);
Nix v. Henry C. Beck Co., 572 So. 2d 1214, 1216 (Ala. 1990) (“The release . . .
was a general release and could have been limited if the parties so desired.”); Reg’l
Health, 565 So. 2d at 114 (“If the parties had wanted to limit the release, they
could have expressly reserved and excepted certain claims, including tort claims,
from the release.”). Ms. Slater did not limit the scope of her “full general release
of all claims” in any fashion, so her release is, in fact, a full and general release of
Notably, Ms. Slater provides no law challenging the plain and ordinary
meaning of “full general release of all claims.” Instead, she makes several
unavailing arguments for why the court should adopt her interpretation of the
phrase. She asserts that claims beyond those brought in this case “have never been
discussed by the parties”; that the parties did not communicate “as to the meaning
of the phrase general release”; that the settlement agreement “explicitly states
that the parties were settling all of the claims in the above-styled case” and “makes
no mention of any potential claims outside of the case before the court”; that the
court has subject matter jurisdiction only over the claims listed in the complaint;
that “[c]learly, the court did not send the parties to mediation to resolve claims that
were not before the court”; that “[a]t no time did the plaintiff contemplate or agree
that she was settling claims outside of the scope of this case”; that Ms. Slater’s
counsel “only represented [her] in this matter as it related to the claims in the
complaint” and thus “had no authority from [Ms. Slater] to act on, or settle any
claims outside of the claims in her complaint”; and that “all of the discussions
regarding settlement . . . [were] based on and centered around the value of the
claims still pending in the lawsuit.” (Doc. 109 at ¶¶ 1–10).
But none of these arguments changes the fact that the phrase “full general
release of all claims” has an unambiguous meaning. And Ms. Slater’s “different
construction of the document does not force the conclusion that the disputed
language is ambiguous.” Wayne J. Griffin, 622 So. 2d at 31. Alabama law
requires the court to ascertain the intent of the parties according to the plain and
clear meaning of the terms in the contract, not according to Ms. Slater’s opinion of
what those plain terms should mean. See id.
Ms. Slater does not cast any doubt on the unambiguous meaning of “full
general release of all claims” to which she and her counsel agreed and she does not
offer any compelling reason for why the court should disregard the phrase’s plain
meaning. So, by separate order, the court will DENY Ms. Slater’s “Motion to
Enforce a Settlement of the Claims before the Court/Motion to Set Case for Trial”
and ORDER Ms. Slater to execute the full general release of all claims proffered
by U.S. Steel and reprinted on page two of Ms. Slater’s motion on or before
January 22, 2019.
DONE and ORDERED this 7th day of January, 2019.
KARON OWEN BOWDRE
CHIEF UNITED STATES DISTRICT JUDGE
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