release rule (Indiana) · Go Syfert
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release rule in Indiana

22 Indiana opinions name it 2 courts 1895–2018 0 in the last five years

The cases below were cited by Indiana courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (9)

CaseFollowedCited
Tru-Cal, Inc. v. Conrad Kacsik Instrument Systems, Inc.green
indctapp · 2009 · cited in 1 Indiana opinions naming this issue, 2018–2018
1 sentence

2018BloomBank maintains that the Release does not bar its breach of contract claims because BloomBank was fraudulently induced into executing the Purchase Agreement containing the Release. 5 *722 Tru-Cal, Inc. v. Conrad Kacsik Instrument Sys., Inc. , 905 N.E.2d 40 , 44 (Ind. Ct. App. 2009) ("The general principle that fraud in the inducement vitiates a contract applies to releases."), trans. denied .

11
Bedwell v. Deboltgreen
ind · 1943 · cited in 1 Indiana opinions naming this issue, 2012–2012
2 sentences

2012See, e.g., Cooper v. Robert Hall Clothes, Inc., 271 Ind. 63 , 390 N.E.2d 155, 157-58 (1979) (citing Bedwell v. DeBolt, 221 Ind. 600 , 50 N.E.2d 875 (1943)) (plaintiffs settlement with two defendant companies released remaining jointly and severally liable defendant).

2012See, e.g., Cooper v. Robert Hall Clothes, Inc., 271 Ind. 63 , 390 N.E.2d 155, 157-58 (1979) (citing Bedwell v. DeBolt, 221 Ind. 600 , 50 N.E.2d 875 (1943)) (plaintiffs settlement with two defendant companies released remaining jointly and severally liable defendant).

11
Cooper v. Robert Hall Clothes, Inc.green
ind · 1979 · cited in 1 Indiana opinions naming this issue, 2012–2012
2 sentences

2012See, e.g., Cooper v. Robert Hall Clothes, Inc., 271 Ind. 63 , 390 N.E.2d 155, 157-58 (1979) (citing Bedwell v. DeBolt, 221 Ind. 600 , 50 N.E.2d 875 (1943)) (plaintiffs settlement with two defendant companies released remaining jointly and severally liable defendant).

2012See, e.g., Cooper v. Robert Hall Clothes, Inc., 271 Ind. 63 , 390 N.E.2d 155, 157-58 (1979) (citing Bedwell v. DeBolt, 221 Ind. 600 , 50 N.E.2d 875 (1943)) (plaintiffs settlement with two defendant companies released remaining jointly and severally liable defendant).

11
Jackson v. Stategreen
ind · 1970 · cited in 1 Indiana opinions naming this issue, 2008–2008
2 sentences

2008Jackson v. State, 253 Ind. 487 , 255 N.E.2d 515, 518 (1970) (De-Bruler J., dissenting.) On certiorari, the Supreme Court adopted Justice DeBru-ler’s dissent and held that the defendant had been deprived of equal protection because the statutes subjected criminal defendants to a more lenient commitment standard and a more stringent release standard than persons not charged with crimes.

2008Jackson v. State, 253 Ind. 487 , 255 N.E.2d 515, 518 (1970) (De-Bruler J., dissenting.) On certiorari, the Supreme Court adopted Justice DeBru-ler’s dissent and held that the defendant had been deprived of equal protection because the statutes subjected criminal defendants to a more lenient commitment standard and a more stringent release standard than persons not charged with crimes.

11
Colgan v. Agway, Inc.green
vt · 1988 · cited in 1 Indiana opinions naming this issue, 1999–1999
2 sentences

1999In Colgan v. Agway, Inc., 150 Vt. 373 , 553 A.2d 143, 146 (1988), the court addressed a situation like the one before us where a provision which purported to release a party from its own negligence was located outside of a release and waiver of Lability clause: Moreover, the purported release is located at the very end of a warranty clause of a performance contract which sets forth with particularity the parties’ respective performance obligations in separate paragraphs.

1999In Colgan v. Agway, Inc., 150 Vt. 373 , 553 A.2d 143, 146 (1988), the court addressed a situation like the one before us where a provision which purported to release a party from its own negligence was located outside of a release and waiver of Lability clause: Moreover, the purported release is located at the very end of a warranty clause of a performance contract which sets forth with particularity the parties’ respective performance obligations in separate paragraphs.

11
Wecker v. Kilmergreen
ind · 1973 · cited in 1 Indiana opinions naming this issue, 1992–1992
2 sentences

1992See Griffin v. Carmel Bank & Trust Co. (1987), Ind.App., 510 N.E.2d 178, 182 , citing Wecker v. Kilmer (1973), 260 Ind. 198 , 294 N.E.2d 132 .

1992See Griffin v. Carmel Bank & Trust Co. (1987), Ind.App., 510 N.E.2d 178, 182 , citing Wecker v. Kilmer (1973), 260 Ind. 198 , 294 N.E.2d 132 .

11
Griffin v. Carmel Bank & Trust Co.green
indctapp · 1987 · cited in 1 Indiana opinions naming this issue, 1992–1992
2 sentences

1992See Griffin v. Carmel Bank & Trust Co. (1987), Ind.App., 510 N.E.2d 178, 182 , citing Wecker v. Kilmer (1973), 260 Ind. 198 , 294 N.E.2d 132 .

1992See Griffin v. Carmel Bank & Trust Co. (1987), Ind. App., 510 N.E.2d 178, 182 , citing Wecker v. Kilmer (1973), 260 Ind. 198 , 294 N.E.2d 132 .

11
Gumberts v. Greenberggreen
indctapp · 1953 · cited in 1 Indiana opinions naming this issue, 1989–1989
2 sentences

1989LaFrenz v. Lake County Fair Board (1977), 172 Ind.App. 389, 392 , 360 N.E.2d 605, 607 ; see also Gumberts v. Greenberg (1953), 124 Ind.App. 138, 145 , 115 N.E.2d 504, 507 , (Generally, where there is no fraud or overreaching involved and the parties' intent to settle for unknown injuries is clearly expressed, a release is a bar to recovery for injuries subsequently discovered.) Therefore, the parties to the present case were free to include in the purchase agreement a provision releaging the Lechners from liability arising out of even latent defects. 3 The trial court erred in failing to recog

1989LaFrenz v. Lake County Fair Board (1977), 172 Ind.App. 389, 392 , 360 N.E.2d 605, 607 ; see also Gumberts v. Greenberg (1953), 124 Ind.App. 138, 145 , 115 N.E.2d 504, 507 , (Generally, where there is no fraud or overreaching involved and the parties' intent to settle for unknown injuries is clearly expressed, a release is a bar to recovery for injuries subsequently discovered.) Therefore, the parties to the present case were free to include in the purchase agreement a provision releaging the Lechners from liability arising out of even latent defects. 3 The trial court erred in failing to recog

11
Miller v. Grieselgreen
ind · 1974 · cited in 1 Indiana opinions naming this issue, 1976–1976
2 sentences

1976See Miller v. Griesel (1974), 261 Ind. 604 , 308 N.E.2d 701 .

1976See Miller v. Griesel (1974), 261 Ind. 604 , 308 N.E.2d 701 .

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Indiana. Read the followed side critically anyway.

Also cited on this issue (22)

CaseCitedYears
Huffman v. Monroe County Community School Corp. green
ind · 1992
2 sentences

2012Corp., 588 N.E.2d 1264 (Ind.1992).

2012Id. at 1266 (citing Restatement (Second) of Judgments § 50 (1982); Restatement (Second) of Torts §§ 885, 886 (1979); 3 Harper, Gray & James, The Law of Torts 37 (2d ed., 1986)).

51995–2012
Plumley v. Stanelle green
indctapp · 1974
1 sentence

2012Id. at 279 .

12012–2012
Jackson v. Indiana green
scotus · 1972
2 sentences

2008Jackson, 406 U.S. at 730 , 92 S.Ct. 1845 .

2008Jackson, 406 U.S. at 730 , 92 S.Ct. 1845 .

12008–2008
Farm Bureau Mutual Ins. Co. v. Seal, Admr. green
indctapp · 1962
2 sentences

1999E.g., Farm Bureau, 134 Ind.App. at 277 , 179 N.E.2d at 763 .

1999E.g., Farm Bureau, 134 Ind.App. at 277 , 179 N.E.2d at 763 .

11999–1999
Dobson v. Citizens Gas and Coke Utility green
indctapp · 1994
1 sentence

1995Huffman v. Monrce County Community School Corp. (1992) Ind., 588 N.E.2d 1264 ; Arnold v. Burton (1995) Ind.App., 651 N.E.2d 1202 ; Dobson v. Citizens Gas and Coke Utility (1994) Ind.App., 634 N.E.2d 1343 .

11995–1995
Arnold v. Burton green
indctapp · 1995
1 sentence

1995Huffman v. Monrce County Community School Corp. (1992) Ind., 588 N.E.2d 1264 ; Arnold v. Burton (1995) Ind.App., 651 N.E.2d 1202 ; Dobson v. Citizens Gas and Coke Utility (1994) Ind.App., 634 N.E.2d 1343 .

11995–1995
Huffman v. Monroe County Community School Corp. green
indctapp · 1991
2 sentences

1992Additionally, the Court of Appeals expressed its displeasure with the rule, while affirming the trial court's entry of summary judgment in the present case, by stating: "In any event, regardless of whether the release rule has ever constituted anything but an abomination in law, we must follow our supreme court's precedents of Bellew, supra and Cooper, supra." 564 N.E.2d at 965 .

1992Additionally, the Court of Appeals expressed its displeasure with the rule, while affirming the trial court's entry of summary judgment in the present case, by stating: "In any event, regardless of whether the release rule has ever constituted anything but an abomination in law, we must follow our supreme court's precedents of Bellew, supra and Cooper, supra." 564 N.E.2d at 965 .

11992–1992
Young v. Hoke green
indctapp · 1986
2 sentences

1991She noted further that the Indiana Supreme Court has continued to adhere to the release rule despite intense criticism. - For example, Judge Barker noted Judge Garrard's excellent criticism of the rule in his dissenting opinion in Young v. Hoke (1986), Ind.App., 493 N.E.2d 1279 trans. denied.

1991For example, Judge Barker noted Judge Garrard's excellent criticism of the rule in his dissenting opinion in Young v. Hoke (1986), Ind. App., 493 N.E.2d 1279 trans. denied.

11991–1991
LaFrenz v. Lake County Fair Board green
indctapp · 1977
2 sentences

1989LaFrenz v. Lake County Fair Board (1977), 172 Ind.App. 389, 392 , 360 N.E.2d 605, 607 ; see also Gumberts v. Greenberg (1953), 124 Ind.App. 138, 145 , 115 N.E.2d 504, 507 , (Generally, where there is no fraud or overreaching involved and the parties' intent to settle for unknown injuries is clearly expressed, a release is a bar to recovery for injuries subsequently discovered.) Therefore, the parties to the present case were free to include in the purchase agreement a provision releaging the Lechners from liability arising out of even latent defects. 3 The trial court erred in failing to recog

1989LaFrenz v. Lake County Fair Board (1977), 172 Ind.App. 389, 392 , 360 N.E.2d 605, 607 ; see also Gumberts v. Greenberg (1953), 124 Ind.App. 138, 145 , 115 N.E.2d 504, 507 , (Generally, where there is no fraud or overreaching involved and the parties' intent to settle for unknown injuries is clearly expressed, a release is a bar to recovery for injuries subsequently discovered.) Therefore, the parties to the present case were free to include in the purchase agreement a provision releaging the Lechners from liability arising out of even latent defects. 3 The trial court erred in failing to recog

11989–1989
Aro Manufacturing Co. v. Convertible Top Replacement Co. green
scotus · 1964
2 sentences

1978A much later case, Aro Manufacturing Co., Inc. v. Convertible Top Replacement Co., Inc. (1964), 377 U.S. 476, 500 , 84 S.Ct. 1526, 1540 , 12 L.Ed.2d 457 , has almost nothing to say about the history or theory of either the old or the new rule.

1978A much later case, Aro Manufacturing Co., Inc. v. Convertible Top Replacement Co., Inc. (1964), 377 U.S. 476, 500 , 84 S.Ct. 1526, 1540 , 12 L.Ed.2d 457 , has almost nothing to say about the history or theory of either the old or the new rule.

11978–1978
Hanson v. Northern States Power Co. green
minn · 1936
2 sentences

1953Hanson v. Northern States Power Co. (1936), 198 Minn. 24 , 268 N. W. 642 ; Berry v. Struble (1937), 20 Cal. App. 2d 299 , 66 P. 2d 746 . *146 *145 This court recently upheld the rescission of a release contract, somewhat similar to that here involved, be *146 cause of a mutual mistake of fact by the parties.

1953Hanson v. Northern States Power Co. (1936), 198 Minn. 24 , 268 N. W. 642 ; Berry v. Struble (1937), 20 Cal. App. 2d 299 , 66 P. 2d 746 . *146 *145 This court recently upheld the rescission of a release contract, somewhat similar to that here involved, be *146 cause of a mutual mistake of fact by the parties.

11953–1953
Berry v. Struble green
calctapp · 1937
2 sentences

1953Hanson v. Northern States Power Co. (1936), 198 Minn. 24 , 268 N. W. 642 ; Berry v. Struble (1937), 20 Cal. App. 2d 299 , 66 P. 2d 746 . *146 *145 This court recently upheld the rescission of a release contract, somewhat similar to that here involved, be *146 cause of a mutual mistake of fact by the parties.

1953Hanson v. Northern States Power Co. (1936), 198 Minn. 24 , 268 N. W. 642 ; Berry v. Struble (1937), 20 Cal. App. 2d 299 , 66 P. 2d 746 . *146 *145 This court recently upheld the rescission of a release contract, somewhat similar to that here involved, be *146 cause of a mutual mistake of fact by the parties.

11953–1953
McLean v. Equitable Life Assurance Society of the United States neutral
wyo · 1884
1 sentence

1941McLean, Administrator v. Equitable Life Assurance Society of the U. S. (1885), 100 Ind. 127 , 50 Am.

11941–1941
Allen v. Kitchen green
idaho · 1909
2 sentences

1921This cannot be done.” In Allen v. Kitchen (1909), 16 Idaho 133 , 100 Pac. 1052 , L.

1921This cannot be done.” In Allen v. Kitchen (1909), 16 Idaho 133 , 100 Pac. 1052 , L.

11921–1921
Steward v. . Albany Insurance Company neutral
ny · 1904
1 sentence

1913Supp. 508 , affirmed in (1904) 179 N. Y. 544 , 71 N. E. 1141 , it was held that a contract between a superintendent of a street railway company, in behalf of the company for life employment, in consideration of a release of his claim, was upheld, since the company retained the release, and thereby accepted the benefit of the contract.

11913–1913
People Ex Rel. Hurley v. . Roosevelt neutral
ny · 1904
1 sentence

1913Supp. 508 , affirmed in (1904) 179 N. Y. 544 , 71 N. E. 1141 , it was held that a contract between a superintendent of a street railway company, in behalf of the company for life employment, in consideration of a release of his claim, was upheld, since the company retained the release, and thereby accepted the benefit of the contract.

11913–1913
Glassburn v. Deer neutral
ind · 1895
1 sentence

1903Stauffer v. Salimonie Mining, etc., Co., 147 Ind. 71 , and cases cited; Manlove v. State, 153 Ind. 80 , and cases cited; McGrew v. Grayston, 144 Ind. 165, 167 , and authorities cited; Glass- burn v. Deer, 143 Ind. 174, 183 , and authorities cited; Sonntag v. Klee, 148 Ind. 536 .

11903–1903
McGrew v. Grayston neutral
ind · 1895
1 sentence

1903Stauffer v. Salimonie Mining, etc., Co., 147 Ind. 71 , and cases cited; Manlove v. State, 153 Ind. 80 , and cases cited; McGrew v. Grayston, 144 Ind. 165, 167 , and authorities cited; Glass- burn v. Deer, 143 Ind. 174, 183 , and authorities cited; Sonntag v. Klee, 148 Ind. 536 .

11903–1903
Stauffer v. Salimonie Mining & Gas Co. green
ind · 1897
1 sentence

1903Stauffer v. Salimonie Mining, etc., Co., 147 Ind. 71 , and cases cited; Manlove v. State, 153 Ind. 80 , and cases cited; McGrew v. Grayston, 144 Ind. 165, 167 , and authorities cited; Glass- burn v. Deer, 143 Ind. 174, 183 , and authorities cited; Sonntag v. Klee, 148 Ind. 536 .

11903–1903
Sonntag v. Klee neutral
ind · 1897
1 sentence

1903Stauffer v. Salimonie Mining, etc., Co., 147 Ind. 71 , and cases cited; Manlove v. State, 153 Ind. 80 , and cases cited; McGrew v. Grayston, 144 Ind. 165, 167 , and authorities cited; Glass- burn v. Deer, 143 Ind. 174, 183 , and authorities cited; Sonntag v. Klee, 148 Ind. 536 .

11903–1903
Manlove v. State green
ind · 1899
1 sentence

1903Stauffer v. Salimonie Mining, etc., Co., 147 Ind. 71 , and cases cited; Manlove v. State, 153 Ind. 80 , and cases cited; McGrew v. Grayston, 144 Ind. 165, 167 , and authorities cited; Glass- burn v. Deer, 143 Ind. 174, 183 , and authorities cited; Sonntag v. Klee, 148 Ind. 536 .

11903–1903
Spaulding v. Crane neutral
· 1873
11895–1895

Where else courts name it

NY 97 (1843–2025) CA 96 (1920–2025) TX 77 (1904–2024) IL 49 (1902–2025) FL 38 (1932–2021) PA 37 (1914–2025) LA 35 (1919–2021) MI 23 (1935–2024) GA 23 (1927–2020) MA 23 (1899–2020) IN 22 (1895–2018) MD 21 (1928–2025) NC 21 (1927–2021) AL 20 (1855–2016) NJ 19 (1931–2026) AZ 18 (1966–2023) WA 18 (1937–2026) WV 17 (1916–2018) MO 16 (1921–2015) OR 16 (1919–2025) OH 15 (1951–2025) DE 15 (1973–2026) WI 14 (1882–2021) VA 14 (1851–2017) MN 13 (1889–2024) IA 12 (1915–2019) KY 10 (1916–2019) CO 9 (1960–1998) NM 8 (1938–2023) AR 7 (1891–2007) SC 7 (1897–2024) TN 6 (1985–2015) VT 6 (1933–2022) KS 6 (1922–2013) SD 5 (1962–2016) AK 5 (1984–2026) MS 5 (1924–2019) WY 5 (1936–2011) DC 5 (1979–2001) UT 5 (1920–2020) CT 5 (1836–2019) NV 4 (1965–2013) NH 4 (1851–2019) RI 4 (1916–2021) MT 3 (1919–2017) OK 3 (1918–1924) HI 3 (1997–2013) ID 3 (1982–1995) ME 3 (1984–2022)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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