## Facts

- Doyle H. Jaynes, a railroad employee, alleged he was injured in a workplace accident and sued under the Federal Employers’ Liability Act (FELA).
- After the accident, a railroad-selected physician permitted Jaynes to return to work.
- About ten days after returning to work, Jaynes signed a release in exchange for $1,312.
- The release broadly purported to discharge the railroad from claims arising from the accident, including “injuries not now known whether or not the undersigned has been advised by doctors or others in any way.”
- Jaynes later contended his condition was more serious than understood at settlement and sought to avoid the release on the theory of mutual mistake as to the nature of his injury.
- The railroad asserted the release and payment constituted an accord and satisfaction barring the FELA claim.

## Issues

1. Whether the railroad was entitled to summary judgment on its accord-and-satisfaction defense based on the release, where Jaynes asserted mutual mistake as to the nature of his injury.
2. Whether, after a jury verdict for Jaynes, the railroad was entitled to judgment notwithstanding the verdict (JNOV) based on the asserted binding effect of the release and insufficiency of the evidence.

## Decision

- The court denied the railroad’s motion for summary judgment.
- The court held genuine disputes of material fact existed concerning the validity and effect of the release and the asserted accord and satisfaction.
- The court denied the railroad’s JNOV motion, leaving the jury’s verdict for Jaynes undisturbed.

## Legal Principles

- Summary judgment is improper when genuine issues of material fact exist; evidence and reasonable inferences are viewed in the light most favorable to the nonmovant.
- The validity of a release challenged in a FELA case is governed by federal law.
- Under federal law, a FELA release may be set aside for mutual mistake.
- A mutual mistake concerning the expected course of recovery (prognosis) is generally insufficient to avoid a release; a mutual mistake concerning the nature of the injury may be sufficient.
- Broad release language purporting to cover unknown injuries is relevant but not necessarily conclusive where the employee produces evidence of a qualifying mutual mistake.

## Conclusion

The court refused to dispose of the FELA claim as a matter of law because the record contained fact disputes about what the parties understood when executing the release and whether any mutual mistake concerned the injury’s nature; after trial, it likewise declined to overturn the jury’s rejection of the railroad’s release-based defense by granting JNOV.


Jaynes v. Louisville & Nashville R.R. Co., 560 F. Supp. 57 (E.D. Tenn. 1981)