This opinion will be unpublished and may
not be cited except as provided by
Minn. Stat. ß 480A.08, subd. 3 (1998).
STATE OF MINNESOTA
IN COURT OF APPEALS
The Regents of the University of Minnesota,
Filed December 28, 1999
Hennepin County District Court
File No. 1980428509
Mark B. Rotenberg, General Counsel, Jeffrey G. Vigil, Associate General Counsel, University of Minnesota, 325 Morrill Hall, 100 Church Street Southeast, Minneapolis, MN 55455 (for respondent)
Paul Scheurer, 635 Erie Street Southeast, Apartment Upper, Minneapolis, MN 55414 (pro se appellant)
Considered and decided by Halbrooks, Presiding Judge, Lansing, Judge, and Shumaker, Judge.
U N P U B L I S H E D O P I N I O N
Paul Scheurer appeals from an order denying his motion to enforce a settlement agreement reached with the University of Minnesota in an unlawful-detainer action. Scheurer claims the district court erred in construing the agreementís general release to be limited to housing-related claims. Because the release unambiguously discharges both parties from "all liabilities and claims" arising before the agreement, we are compelled to reverse.
Paul Scheurer and the Regents of the University of Minnesota executed a stipulated settlement agreement in connection with an unlawful-detainer action. The agreement included a general release discharging both parties from "all liabilities and claims arising prior to the date of this Agreement." When the University later took action to collect on Scheurerís educational and medical debts, Scheurer moved to enforce the settlement agreement, claiming it released him of all claims, including claims based on his educational and medical debts to the University. The district court denied Scheurerís motion, holding that the release applied only to housing-related claims. This appeal followed.
D E C I S I O N
Minnesota law encourages the settlement of disputes and generally presumes the validity of claims releases. Sorensen v. Coast-to-Coast Stores, Inc., 353 N.W.2d 666, 669 (Minn. App. 1984), review denied (Minn. Nov. 7, 1984). A release is a contract. Couillard v. Charles T. Miller Hosp., Inc., 253 Minn. 418, 426 n.2, 92 N.W.2d 96, 101 n.2 (1958). The interpretation of a contract raises a question of law, which we review de novo. See Frost-Benco Elec. Assín v. Minnesota Pub. Utils. Commín, 358 N.W.2d 639, 642 (Minn. 1984) ("[A]n appellate court need not give deference to a trial courtís decision on a legal issue.").
When the terms of a contract are ambiguous, the court must "ascertain and give effect to the intention of the parties." Metropolitan Sports Facilities Commín v. General Mills, Inc., 470 N.W.2d 118, 122-23 (Minn. 1991) (citation omitted). When the terms of a contract are unambiguous, on the other hand, the court need look no further than the document itself to ascertain the partiesí intent. Id. at 123. Minnesota law "presumes that parties to a release agreement intend what is expressed in a signed writing." Sorensen, 353 N.W.2d at 670.
The University has not overcome this presumption. The release negotiated with Scheurer discharges "all liabilities and claims arising prior to the date of this Agreement." The language of the release is unambiguous. See Pilon v. University of Minnesota, 710 F.2d 466, 467 (8th Cir. 1983) (agreement releasing the University from "any and all manner of action or actions * * * which [plaintiff] ever had" left no doubt that plaintiff waived all potential claims against the University); Somora v. Marriott Corp., 812 F.Supp. 917, 921 (D.Minn. 1993) (agreement releasing employer from all liability arising from termination of employeeís employment was unambiguous); West Am. Ins. Co. v. Ford Motor Co., 759 F.Supp. 547, 549 (D.Minn. 1991) (release discharging "all" claims against "all" persons who might be liable for injuries relating to car accident unambiguously released insurerís products liability claim against manufacturer). The release is also short, common, and straightforward. See Sorensen, 353 N.W.2d at 669 ("The more complicated, confusing or misleading the language[,] the more weight a court will give to a claim of no intent."). As a matter of policy, courts cannot disregard straightforward language in the manner the University proposes if parties are to be able to rely on releases to settle their differences. See West Am., 759 F.Supp. at 551.
We infer from the Universityís argument that, by using broad language and failing to restrict it, the University may have released more claims than it intended to release. Unilateral mistakes are insufficient to invalidate a release, however. Spitzmueller v. Burlington N. R.R. Co., 740 F.Supp. 671, 676 (D. Minn. 1990). It is categorically settled in Minnesota that a partyís outward manifestation of assent, rather than its subjective intention, is determinative. Cedarstrand v. Lutheran Bhd., 263 Minn. 520, 532, 117 N.W.2d 213, 221 (1962) ("Expressions of mutual assent, by words or conduct, must be judged objectively, not subjectively.").
The general release in the partiesí settlement agreement unambiguously discharged not just housing-related claims, but all claims and liabilities the University had against Scheurer arising before the date of the release.