## Facts

- A Brown University student, William R. McCormick III, was accused by fellow student Marcella E. Dresdale of sexual assault.
- Brown University administrators handled the accusation in a manner that, according to McCormick, culminated in his withdrawal from the university and loss of a full scholarship.
- McCormick denied the allegation and asserted it was false and made in bad faith; his parents also claimed harm tied to the university’s actions and the accusation’s fallout.
- The parties later executed a written settlement agreement containing mutual general releases.
- Dresdale’s release purported to “release and discharge McCormick from any and all claims” including allegations of misconduct at Brown.
- McCormick’s release purported to “release and discharge Dresdale from any and all claims” including defamation.
- Despite the settlement, McCormick and his parents sued Dresdale, her parents, Brown University, and Brown administrators, asserting defamation and other tort-based claims tied to the accusation, the university’s response, and related conduct.
- Defendants moved to dismiss under Rule 12(b)(6), arguing the settlement releases barred the suit.

## Issues

1. Whether the settlement agreement’s broad mutual releases barred the plaintiffs’ claims as a matter of law at the Rule 12(b)(6) stage.
2. Whether the court could enforce the releases on the pleadings despite plaintiffs’ allegations that the accusations were false, made in bad faith, and tied to coercive or inequitable circumstances surrounding the settlement and ensuing conduct.
3. Whether the pleadings required factual development to determine the scope and enforceability of the releases as applied to the asserted claims.

## Decision

- The court denied the motions to dismiss.
- Accepting the complaint’s allegations as true and drawing reasonable inferences for plaintiffs, the court held defendants had not established that the releases unambiguously barred the action as a matter of law at the pleading stage.
- The court allowed the case to proceed so the parties could develop a factual record bearing on the settlement, its scope, and enforceability.

## Legal Principles

- On a Rule 12(b)(6) motion, the court accepts well-pleaded factual allegations as true and does not resolve factual disputes or weigh competing narratives.
- A settlement release is construed under ordinary contract principles, and broad “any and all claims” language can extinguish a wide range of claims.
- A release defense may be unsuitable for resolution on the pleadings where the complaint plausibly alleges facts that could affect enforceability or scope (including alleged fraud, bad faith, coercion, or overreaching).
- When the application of a release depends on contested facts about the agreement’s formation or the relationship between the released matters and the pleaded claims, dismissal may be denied to permit factual development.

## Conclusion

The court refused to dismiss claims based solely on a settlement agreement’s general releases where the complaint plausibly alleged that the underlying accusations were false and made in bad faith and raised fact-dependent disputes about the releases’ scope and enforceability, requiring development beyond the pleadings.


McCormick v. Dresdale, No. 09-cv-474-PB (D.R.I. May 28, 2010)