Woyma v. Ciolek

Woyma (plaintiff) suffered whiplash when Shackleford rear-ended her car; she experienced some headaches and neck pain but appeared to have no serious injuries. Shackleford's insurer paid for her car repairs and $25 covering her x-ray and initial pain and suffering, then sent a broad release covering both known and unknown injuries, which Woyma signed without consulting a lawyer, believing she had no lasting injuries. A year later she developed new symptoms traced to a latent back injury from the crash and sued Ciolek (defendant), Shackleford's estate administrator, for the new treatment costs; the trial court set aside the release, and a jury awarded her $22,500.

Whether the doctrine of mutual mistake applies to release agreements.