Mark Peak v. Ellis Adams and Rachel Adams
2011 Iowa Sup. LEXIS 45
Iowa2011Background
- Peak signed a Release of All Claims for $20,000 under Republic Western/U-Haul; the release named Ellis Adams but did not name Rachel Adams.
- Peak was injured Feb. 22, 2008 while moving furniture with Ellis and Rachel Adams using a U-Haul; injury led to medical expenses over $50,000.
- Country Mutual insured the Adamses’ auto policy; Republic Western paid the $20,000 limits and issued the release.
- Peak’s attorney prepared and sent the release and an amended release attempt followed after Country Mutual questioned coverage; Peak received $6,000 net after medical liens and fees.
- The district court granted summary judgment for Ellis, while the court of appeals reversed on Rachel; the Iowa Supreme Court granted review to resolve the contract interpretation and release scope issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Release unambiguously discharged Ellis Adams | Peak intended only U-Haul; Ellis not personally released | Release language unambiguously discharged Ellis Adams | Yes, Ellis Adams discharged by express terms |
| Whether Rachel Adams was released by the release | Release of all claims includes Rachel as a released party | Language insufficient to discharge unnamed customer | Question of fact; not discharged as a matter of law |
| Whether an agency relationship existed to release Rachel | Agency through Ellis Adams; Rachel released as his agent | No definitive agency relationship shown | Agency issue for fact-finder on remand |
| Whether the phrase any and all aspects of the rental includes customers | Phrase intended to cover all involved in rental | Phrasing too broad/unidentified customers; not released | Ambiguous; not to discharge Rachel; remand necessary |
Key Cases Cited
- Fashion Fabrics of Iowa, Inc. v. Retail Investors Corp., 266 N.W.2d 22 (Iowa 1978) (contract interpretation; focus on party intent; noscitur rule not mandatory)
- Waechter v. Aluminum Co. of America, 454 N.W.2d 565 (Iowa 1990) (settlement agreements favored; avoid re-litigation; interpret in light of intent)
- Aid Ins. Co. v. Davis Cnty., 426 N.W.2d 631 (Iowa 1988) (no discharge of unspecified parties unless named or identified)
- Shaer v. Webster Cnty., 644 N.W.2d 327 (Iowa 2002) (meeting of the minds required for releases; extrinsic evidence limited)
- Covenant Clinic v. Wells Dairy, Inc., 752 N.W.2d 430 (Iowa 2008) (summary judgment standard; reliance on undisputed facts)