Jessla Construction Corp. v. Miami-Dade County School Board, 2010 Fla. App. LEXIS 17676

Jessla filed a wrongful termination claim against the School Board in 2001.
The School Board served a Proposal for Settlement under §768.79 and Rule 1.442 on March 21, 2008, offering $1,000 to resolve all claims.
The Proposal required a broad Unconditional General Release attached as Exhibit A.
The General Release purportedly discharged School Board and its affiliates and potential nonparties.
The Demand Letter of March 26, 2008 warned that dismissal with prejudice would forgo fees, otherwise fees would be sought if the matter was litigated.
A bench trial resulted in a final judgment in favor of the School Board, and Jessla appealed challenging the fee award and the Proposal’s validity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the Demand Letter invalidate or withdraw the Proposal for Settlement?	Jessla argues the Demand Letter invalidates or withdraws the Proposal.	School Board contends the Demand Letter did not affect the Proposal’s validity.	Demand Letter did not affect validity; Proposal stands.
Is the General Release compliant with Rule 1.442(c)(2)(A) and not rendering the Proposal ambiguous?	General Release improperly extends to nonparties, rendering the Proposal defective.	Language is standard in releases and not too broad or ambiguous.	Release language is typical and does not render the Proposal defective.
Should Bowman and Carey-All guide interpretation of the Proposal’s validity?	Argues the nonparty language undermines enforceability.	Relies on Bowman and Carey-All to deem common release language acceptable.	Trial court’s interpretation is affirmed; Proposal complies with 1.442 and 768.79.

Board of Trustees of Florida Atlantic Univ. v. Bowman, 853 So.2d 507 (Fla. 4th DCA 2003) (general-release language is typically unambiguous and not invalidating)
Carey-All Transp., Inc. v. Newby, 989 So.2d 1201 (Fla. 2d DCA 2008) (general-release language defining parties is not too broad)