Reinier Razon began working for Southern California Permanente Medical Group at its Kaiser Sunset location in January 2014, as a clinical laboratory scientist.

In 2016 Razon was involved in a dispute with Darren Wallace, the union steward assigned to the clinical laboratory scientists. According to Razon, Wallace assaulted him. Razon was treated two days later at the Kaiser emergency room for anxiety and diagnosed with “emotional stress reaction,” which he believed was due to his encounter with Wallace.

Razon filed a workers’ compensation claim for stress and anxiety arising from his encounter with Wallace. That claim was pending when he filed his lawsuit against SCPMG in April 2017, for disability discrimination, failure to accommodate and failure to engage in the interactive process in violation of the California Fair Employment and Housing Act.

In March 2018 Razon settled his workers’ compensation claim for $45,000, as reflected in a standard, preprinted compromise and release form. He also signed a separate voluntary resignation letter. The document states it “releases Kaiser from any and all claims, known or unknown, which may exist at the time of execution of this Agreement.” It specifically included “causes of action under Title VII of the Civil Rights Act of 1964 (race, color, religion, sex and national origin discrimination); the Americans with Disabilities Act; 29 USC section 62 (age discrimination). However, this list is expressly understood by the parities [sic] not to be all-inclusive.”

The trial court granted SCPMG’s motion for summary judgment and entered judgment in favor of SCPMG, ruling Razon’s civil FEHA lawsuit was barred by his written release of all claims relating to his employment with SCPMG. The court of appeal affirmed the dismissal in the unpublished case of Razon v. Southern California Permanente.

Razon argues the release set forth in his voluntary resignation letter is enforceable only if the letter was attached to the preprinted compromise and release form used to resolve his workers’ compensation claims. No authority cited by Razon established attachment as a requirement. To the contrary, the Supreme Court in Claxton Court (34 Cal.4th at pp. 370, 378) expressly recognized release of the non-workers’ compensation claims could be effected through a separate document, independent of the workers’ compensation preprinted form. That is exactly what occurred here

Razon argues the absence of any express reference to his FEHA claims in the release creates a triable issue of fact whether the lawsuit, pending at the time the release was executed, was included within its scope. The Supreme Court in Claxton expressly rejected the need for the specificity that Razon suggests.

In his declaration in opposition to the summary judgment, Razon insisted he did not intend by signing the letter to release his FEHA claims. That undisclosed intent, however, is irrelevant to the interpretation of the release. (Otay Land Co., LLC  v. U.E. Limited, L.P. (2017) 15 Cal.App.5th 806, 855).