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RM ASSOCIATES CONSULTING INC v. CITIZENS PROPERTY INSURANCE CORPORATION (2021)

District Court of Appeal of Florida, Third District.2021-08-04No. No. 3D21-131

Summary

Holding. The court affirmed the lower court's judgment.

The court affirmed the lower court's decision in this dispute between RM Associates Consulting Inc. and Citizens Property Insurance Corporation. The opinion emphasizes that when interpreting settlement agreements and release documents, courts must look primarily to the plain language of the written agreement itself. The court noted that settlement agreements are contracts and must be analyzed using standard contract interpretation principles, which require courts to determine the parties' intent from the actual words they used rather than relying on outside evidence or testimony.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Interpretation of settlement agreement language
  • Application of parol evidence rule to release agreements
  • Whether ambiguity existed in the contractual language
  • Scope of claims released by the settlement agreement

Procedural posture

The appellate court reviewed the lower court's interpretation and enforcement of a settlement agreement and release document between the parties.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

Affirmed. See Hurt v. Leatherby Ins. Co., 380 So. 2d 432, 433 (Fla. 1980) (observing: “As with contracts generally, the language used in the release is the best evidence of the parties intent”); Munoz Hnos, S.A. v. Editorial Televisa Intern., S.A., 121 So. 3d 100, 103 (Fla. 3d DCA 2013) (observing: “Because a settlement agreement is contractual in nature, it is interpreted and governed by contract law”). See also Dirico v. Redland Estates, Inc., 154 So. 3d 355, 357 (Fla. 3d DCA 2014) (holding: “In the absence of some ambiguity, the intent of the parties to a written contract must be ascertained from the words used in the contract, without resort to extrinsic evidence”; further observing that a “true ambiguity does not exist [in a contract] merely because [the] contract can possibly be interpreted in more than one manner” but “only when contractual language ‘is susceptible to more than one reasonable interpretation’ ”) (quotations omitted); Bird Lakes Dev. Corp. v. Meruelo, 626 So. 2d 234, 237 (Fla. 3d DCA 1993) (holding: “The parol evidence rule ‘serves as a shield to protect a valid, complete and unambiguous written instrument from any verbal assault that would contradict, add to, or subtract from it, or affect its construction’ ”) (quoting Sears v. James Talcott, Inc., 174 So. 2d 776, 778 (Fla. 2d DCA 1965)); Patco Transp., Inc. v. Estupinan, 917 So. 2d 922, 923 (Fla. 1st DCA 2005) (holding release signed by employee in settlement of negligence action against his employer and others, releasing employer from “any and all past, present or future claims, demands, obligations, actions, causes of action, rights, damages, costs, losses of services, expenses and compensation of any nature whatsoever, whether based on a tort, contract or other theory of recovery, which the Plaintiff now has, or which may hereafter accrue or otherwise be acquired, on account of, or may in any way grow out of, or which are the subject of the Complaint․” released employer from employees subsequent petition for workers compensation benefits).

PER CURIAM.