Mich. Comp. Laws » Michigan Compiled Laws / Chapter 600 / Act 236 of 1961
Michigan Compiled Laws

Mich. Comp. Laws § 600.2925d (2026)

Effect of release, covenant not to sue, or covenant not to enforce judgment.

✓ current as of July 2026
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REVISED JUDICATURE ACT OF 1961


Act 236 of 1961


600.2925d Effect of release, covenant not to sue, or covenant not to enforce judgment.

Sec. 2925d.

    If a release or a covenant not to sue or not to enforce judgment is given in good faith to 1 of 2 or more persons for the same injury or the same wrongful death, both of the following apply:

    (a) The release or covenant does not discharge 1 or more of the other persons from liability for the injury or wrongful death unless its terms so provide.

    (b) The release or covenant discharges the person to whom it is given from all liability for contribution to any other person for the injury or wrongful death.

History: Add. 1974, Act 318, Imd. Eff. Dec. 15, 1974 ;-- Am. 1995, Act 161, Eff. Mar. 28, 1996

Compiler's Notes:

    Section 3 of Act 318 of 1974 provides: “The provisions of this amendatory act shall apply only to torts committed on or after January 1, 1975.”

Notes of Decisions
Cited in 53 cases (3 in the last 5 years), 1976–2025 · leading case: Theophelis v. Lansing Gen. Hosp., 424 N.W.2d 478 (Mich. 1988).
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Theophelis v. Lansing Gen. Hosp., 424 N.W.2d 478 (Mich. 1988). · cites it 32× “[6] We granted leave to appeal, limited to two issues: (1) whether the settlements reached with Palmer and Gilmore released the hospital from *480 vicarious liability for their actions under MCL 600.2925d; MSA 27A.2925(4); and (2) whether the releases, if not so protected,…”
Velez v. Tuma, 821 N.W.2d 432 (Mich. 2012). · cites it 16× “Considering the general nature and tone of tort reform legislation, we conclude that the Legislature did not intend to allow recovery greater than the actual loss in joint and several liability cases when it deleted the relevant portion of [MCL 600.”
Rittenhouse v. Erhart, 380 N.W.2d 440 (Mich. 1986). · cites it 14× “Moreover, it would not serve the nonsettling defendants' goal of limiting their liability to attempt to show that the settlers were more the cause of the plaintiffs' injuries than they. This is so because if the nonsettler was found to be negligent and the cause of the…”
Shay v. Aldrich, 790 N.W.2d 629 (Mich. 2010). · cites it 4× “23 In contrast, the partial dissent opined that when a “stranger” to a release seeks to apply broad language contained in a release to bar claims against the stranger, it is appropriate for a court to consider parol evidence of intent in order to determine the true scope of the…”
Markley v. Oak Health Care Investors of Coldwater, Inc, 660 N.W.2d 344 (Mich. Ct. App. 2003). · cites it 6× “With regard to the requested $220,000 setoff against the $300,000 verdict, the trial court ruled that the amendment of MCL 600.2925d, which until the enactment of 1995 tort reform legislation had expressly allowed a setoff against a judgment predicated on an earlier settlement…”
Mayhew v. Berrien Cnty. Road Comm'n, 326 N.W.2d 366 (Mich. 1982). · cites it 7× “Introduction Defendants, by motion, challenged the continuing validity of the contribution-release statute, MCL 600.2925d; MSA 27A.2925(4) 1 in face of "the adoption of the doctrine of pure comparative negligence in Michigan.”
Zaremba Equip., Inc. v. Harco Nat'l Ins., 761 N.W.2d 151 (Mich. Ct. App. 2008). · cites it 2× “(b) The percentage of the total fault of all persons that contributed to the death or injury, including each plaintiff and each person released from liability under [MCL 600.2925d], regardless of whether the person was or could have been named as a party to the action.”
Romska v. Opper, 594 N.W.2d 853 (Mich. Ct. App. 1999). · cites it 6× “[MCL 600.2925d; MSA 27A.2925(4) (emphasis added).”
Lincoln v. Gupta, 370 N.W.2d 312 (Mich. Ct. App. 1985). · cites it 4× “Plaintiff cited the contribution statute, MCL 600.2925d; MSA 27A.2925(4), for the proposition that the covenant not to sue did not discharge the hospital from liability.”
Felsner v. McDonald Rent-A-Car, Inc, 484 N.W.2d 408 (Mich. Ct. App. 1992). · cites it 5× “That section provides, in pertinent part: *568 When a release or a covenant not to sue or not .”
Romain v. Frankenmuth Mut. Ins., 762 N.W.2d 911 (Mich. 2009). · cites it 2× “(b) The percentage of the total fault of all persons that contributed to the death or injury, including each plaintiff and each person released from liability under [MCL 600.2925d], regardless of whether the person was or could have been named as a party to the action.”
Lowe v. Est. Motors Ltd., 410 N.W.2d 706 (Mich. 1987). · cites it 2× “See MCL 600.2925d; MSA 27A.2925(4). The propriety of Mr.”
Show all 53 citing cases →
— Mich. Comp. Laws § 600.2925d(a) — 5 cases
Shay v. Aldrich, 790 N.W.2d 629 (Mich. 2010). “23 In contrast, the partial dissent opined that when a “stranger” to a release seeks to apply broad language contained in a release to bar claims against the stranger, it is appropriate for a court to consider parol evidence of intent in order to determine the true scope of the…”
Smith v. Childs, 497 N.W.2d 538 (Mich. Ct. App. 1993).
Indus. Steel Stamping, Inc v. Erie State Bank, 423 N.W.2d 317 (Mich. Ct. App. 1988).
O Heather Malone v. Conor Thompson McRell (Mich. Ct. App. 2023).
Coa 361133 Eric Preston V Abbott Pointe Assocs. Llc Opinion - Per Curiam - Unpublished 3/7/2025 (Mich. Ct. App. 2025).
— Mich. Comp. Laws § 600.2925d(b) — 15 cases
Velez v. Tuma, 821 N.W.2d 432 (Mich. 2012). “Considering the general nature and tone of tort reform legislation, we conclude that the Legislature did not intend to allow recovery greater than the actual loss in joint and several liability cases when it deleted the relevant portion of [MCL 600.”
Velez v. Tuma, 770 N.W.2d 89 (Mich. Ct. App. 2009).
Hall v. Citizens Ins. Co. of Am., 368 N.W.2d 250 (Mich. Ct. App. 1985).
Markley v. Oak Health Care Investors of Coldwater, Inc, 660 N.W.2d 344 (Mich. Ct. App. 2003). “With regard to the requested $220,000 setoff against the $300,000 verdict, the trial court ruled that the amendment of MCL 600.2925d, which until the enactment of 1995 tort reform legislation had expressly allowed a setoff against a judgment predicated on an earlier settlement…”
Indus. Steel Stamping, Inc v. Erie State Bank, 423 N.W.2d 317 (Mich. Ct. App. 1988).
— Mich. Comp. Laws § 600.2925d(c) — 2 cases
DeJong v. B F Goodrich, Inc., 292 N.W.2d 157 (Mich. Ct. App. 1980).
Smith v. Childs, 497 N.W.2d 538 (Mich. Ct. App. 1993).
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