Wright v. Fernandez

Summary

The Delaware Superior Court denied Defendant Davante Fernandez’s motion for summary judgment in Jaleel Wright’s personal-injury action arising from a motor-vehicle accident. The court held that the release Wright executed in exchange for Allstate’s policy-limit payment unambiguously preserved claims against Fernandez because releasing him would adversely affect Wright’s ability to pursue underinsured-motorist benefits. The court therefore concluded that the release did not extinguish Wright’s claims against Fernandez.

Holdings

1. The release was not ambiguous because its provisions, read together, unambiguously preserved claims against persons whose release would adversely affect Wright's ability to recover underinsured-motorist benefits. The court therefore applied the four-corners rule and did not need to consider extrinsic evidence concerning the parties' intent.
2. The release did not extinguish Wright's claims against Fernandez; it expressly preserved them because releasing Fernandez would have adversely affected Wright's ability to perfect and recover underinsured-motorist benefits.
3. Fernandez was not entitled to summary judgment because the release did not bar Wright's claims against him.

Questions Presented

1. Whether the release executed by Wright after Allstate paid its bodily-injury policy limits unambiguously released Fernandez from liability for the accident.
2. Whether the release's reservation of claims necessary to preserve Wright's underinsured-motorist benefits preserved Wright's claims against Fernandez.
3. Whether Fernandez was entitled to summary judgment based on the release.

Disposition

other