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Jaynes v. Louisville & Nashville Railroad

United States District Court for the Eastern District of Tennessee
560 F. Supp. 57 (1981)


Jaynes (plaintiff) was involved in an accident while working for Louisville & Nashville Railroad (railroad) (defendant). The railroad’s doctor allowed Jaynes to return to work. Ten days later, Jaynes signed a document, agreeing to release the railroad from any claim arising out of the accident in exchange for a payment of $1,312. The release specifically included injuries that were unknown at the time of the signing. Jaynes sued the railroad for damages under the Federal Employers’ Liability Act (FELA), 45 USC § 51, claiming that the release was the result of a mutual mistake of the parties as to the nature of Jaynes’s injury. The railroad moved for summary judgment, arguing that Jaynes’s claim was barred by an accord and satisfaction.

Rule of Law


Holding and Reasoning (Neese, J.)

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