Butler v. The Vons Companies, Inc

In Butler v. The Vons Companies, Inc. (2006) 140 Cal.App.4th 943, the court found the subject release agreement, arising out of a workplace altercation and union grievance, was ambiguous on the issue of the scope of the waiver of claims in it. The extrinsic evidence in that case clarified that the parties reasonably understood their release agreement had resolved and settled only the altercation grievance, but not the plaintiff Butler's civil suit alleging employment harassment and discrimination claims. (Gov. Code, 12900 et seq., the Fair Employment and Housing Act (FEHA) right to sue letter.) The court determined that it was a triable question of fact whether the plaintiff and his employer had agreed that the scope of his section 1542 waiver extended, or did not extend, to his separate harassment and discrimination claims. (Butler, supra, at pp. 949-950.)