## Facts

- A. Marie Young drove a 1993 Nissan Altima that collided with another vehicle after Paul Knight ran a stop sign.
- The Altima’s driver-side airbag deployed; Young alleged it deployed with excessive force and caused additional injuries beyond the crash impact.
- Young sued Knight and settled for $5,000.
- Young signed a written “Release of All Claims” that released Knight and “all other persons, firms or corporations” from any claims for injuries arising out of the September 20, 1993 accident.
- After executing the release, Young filed a federal products-liability action against Nissan Motor Corporation in U.S.A., alleging airbag defects caused or enhanced her injuries.

## Issues

1. Whether, under Missouri law, an unambiguous general release discharging the tortfeasor and “all other persons, firms or corporations” for injuries arising from a specified accident also releases a non-party manufacturer from later products-liability claims stemming from the same accident.
2. Whether the plaintiff may avoid the release’s effect based on Nissan not being named, lack of privity, plaintiff’s asserted subjective intent, alleged ambiguity, or claimed inadequacy of consideration.

## Decision

- The court granted Nissan’s motion for summary judgment.
- The court held the release was an unambiguous general release that, by its terms, discharged “all other persons, firms or corporations,” which included Nissan.
- The court dismissed Young’s claims because they arose from the same accident and injuries covered by the release.

## Legal Principles

- A release is a contract; under Missouri law, its meaning is determined from the plain, ordinary meaning of the written terms when unambiguous.
- A general release covering claims arising out of a specified occurrence and releasing “all other persons, firms or corporations” discharges all potential tortfeasors connected to that occurrence, even if not named.
- A releasor’s undisclosed subjective intent cannot contradict an unambiguous release; absent a recognized avoidance theory (e.g., fraud, mutual mistake, or ambiguity), extrinsic evidence will not narrow the release.
- Privity and payment of consideration by the later-asserted defendant are not required for the defendant to benefit from an unqualified general release; consideration need not come from every person discharged.
- Courts do not assess the adequacy of consideration where real consideration was bargained for and received.

## Conclusion

Because Young executed an unambiguous general release for injuries arising from the accident that expressly discharged “all other persons, firms or corporations,” Missouri law required enforcement of its terms, barring her later products-liability claims against Nissan and entitling Nissan to summary judgment.


Young v. Nissan Motor Corp. in U.S.A., 964 F. Supp. 1350 (W.D. Mo. 1997)