LaFleur v. C. C. Pierce Co.
Massachusetts Supreme Judicial Court
496 N.E.2d 827 (1986)
LaFleur (plaintiff) injured his right foot at work, and the company doctor diagnosed only a sprained toe, leading LaFleur to sign a release with the employer's insurer (defendant) barring further claims 'because of this injury.' LaFleur was later diagnosed with a rare arterial disease requiring amputation of both legs, and a doctor testified the workplace accident had actually damaged LaFleur's arterial system, aggravating his preexisting disease and causally leading to the amputations. LaFleur sued to rescind the release, but the trial court entered judgment for the defendants, characterizing LaFleur's situation as simply an incorrect prediction about how a known injury (the sprained toe) might turn out in the future.
Whether a release of personal-injury claims is voidable when, at the time of signing, the parties were mistaken about the existence of an injury rather than merely its future severity.