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Contracts Keyed to Kuney
Jaynes v. Louisville & Nashville Railroad
Facts
Jaynes (plaintiff) was involved in an accident while working for Louisville and Nashville (railroad) (defendant). The railroad's doctor enabled Jaynes to come back to work. After ten days, Jaynes marked a record, consenting to discharge the railroad from any claim emerging out of the accident in return for an installment of $1,312. The discharge particularly included injuries that were unknown at the time of signing. Jaynes sued the railroad for damages under the Federal Employers' Liability Act (FELA), 45 USC § 51, asserting that the discharge was the result of a mutual mistake of the parties with regards to the idea of Jaynes' injury. The railroad moved for summary judgment, arguing that Jaynes’s claim was barred by an accord and satisfaction.
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