Cline v. Homouth CA3

DUARTE, J.,

Concurring. — Although unnecessary to our disposition here, I feel compelled to echo the concerns expressed by my colleagues in other districts regarding the use of “overly broad, loose terms in release agreements.” (Neverkovec v. Fredericks (1999) 74 Cal.App.4th 337, 354 [87 Cal.Rptr.2d 856]; see Hess v. Ford Motor Company (2002) 27 Cal.4th 516, 530 [117 Cal.Rptr.2d 220, 41 P.3d 46].)

The widespread use of global “all other persons” releases raises policy concerns as to fairness. (See Rodriguez v. Oto (2013) 212 Cal.App.4th 1020, 1031 [151 Cal.Rptr.3d 667].) As we see here, the…