Jaynes v. Louisville & Nashville Railroad
United States District Court for the Eastern District of Tennessee
560 F. Supp. 57 (1981)
Jaynes (plaintiff) was hurt in a workplace accident while employed by Louisville & Nashville Railroad (defendant). The railroad's own doctor cleared Jaynes to return to work, and ten days later Jaynes signed a release discharging the railroad from any claim arising from the accident — including unknown injuries — in exchange for $1,312. Jaynes later sued under the Federal Employers' Liability Act (FELA), claiming the release resulted from a mutual mistake about the true nature of his injury. The railroad moved for summary judgment based on accord and satisfaction.
Whether mutual mistake about the nature of a plaintiff's injury is a sufficient basis for voiding a release.