The New York Court of Appeals affirmed the dismissal of a false arrest lawsuit against New York City, ruling that a broad settlement agreement released the plaintiff's claims. The court issued its memorandum decision in *Smith v. City of New York* (2025 NY Slip Op 07081) on December 18, 2025.

Johnte Smith filed two separate false arrest lawsuits against the City of New York in 2021, both stemming from arrests that occurred in 2020. The plaintiff and the city eventually settled the second of these actions through a comprehensive settlement agreement that included extensive release language.

Under the settlement terms, Smith agreed to release the City of New York from "any and all state and federal tort claims, causes of action, suits, occurrences, and damages, whatsoever, known or unknown, including but not limited to state and federal civil rights claims, actions, and damages." The release covered any claims that Smith "had, now has, or hereafter can, shall, or may have" arising from "any matter, cause, or thing whatsoever that occurred through the date of this RELEASE."

The settlement document contained specific warnings to ensure Smith understood the scope of his release. Immediately beneath the release language, in bold and all-capitalized text, the agreement instructed Smith to "list below the exclusion of other actions or claims from this release." The document explicitly warned that the release would cover "all outstanding actions or claims" unless they were "excluded specifically by name."

Despite these clear instructions and warnings, Smith signed the settlement agreement without excluding any claims. His attorney notarized his signature on the document, indicating legal review of the terms.

The legal dispute centered on whether the broad release language in the second case's settlement agreement barred Smith's first false arrest lawsuit against the city. The settlement's comprehensive language appeared to encompass all potential claims against the city arising from incidents through the settlement date, which would include the 2020 arrest that formed the basis of Smith's remaining lawsuit.

The Appellate Division initially dismissed Smith's remaining false arrest claim, finding that the settlement agreement's release provisions applied to bar the lawsuit. Smith appealed this decision to the New York Court of Appeals, the state's highest court, seeking to preserve his remaining claim against the city.

In its memorandum decision, the Court of Appeals unanimously affirmed the Appellate Division's dismissal. The court's brief ruling stated: "The order of the Appellate Division should be affirmed, with costs." By awarding costs to the city, the court emphasized the strength of the defendants' legal position.

The decision reflects well-established principles of contract law regarding settlement agreements and release clauses. Courts generally enforce settlement agreements according to their plain terms, particularly when parties receive adequate consideration and have legal representation. The broad language of Smith's release, combined with the specific warnings about excluding claims and his failure to do so, created a strong legal basis for the city's position.

Brian J. Isaac represented Smith in the appeal, while Amy McCamphill appeared for the city respondents. The case demonstrates the importance of carefully reviewing settlement terms and explicitly excluding any claims that parties wish to preserve for future litigation.

The ruling has broader implications for civil rights litigation against municipalities. Plaintiffs who settle one claim against a government entity while maintaining separate lawsuits must carefully negotiate release language to preserve their remaining cases. The decision reinforces that broadly worded releases will be enforced according to their terms, even when they may bar related claims.

For municipal defendants, the decision validates the use of comprehensive release language in settlement agreements. Cities and other government entities can continue to seek broad releases that protect against future litigation arising from the same time period, provided they give adequate notice to plaintiffs about the scope of the release.

The case also highlights the crucial role of legal counsel in settlement negotiations. Smith's attorney notarized his signature on the agreement, suggesting legal review occurred before signing. This factor likely strengthened the city's argument that Smith knowingly agreed to the broad release terms.

The Court of Appeals' decision is final, as New York's highest court. The case number 116 indicates it was among the court's regular docket of appeals for 2025. The opinion remains subject to revision before publication in the Official Reports, as noted in the court's standard disclaimer.

This ruling serves as a reminder to litigants about the binding nature of settlement agreements and the importance of precise language in legal documents. Future cases involving similar release language disputes will likely reference this decision as precedent for enforcing broadly worded settlement releases in civil rights litigation against government entities.