In Benowski v. Track Dr., LLC affirmed summary judgment dismissing a contractor’s claim for unpaid retainage and other compensation arising from a commercial renovation project. Although the parties never executed a formal written construction contract, the Court enforced a January 2020 release under which the contractor acknowledged that $233,797.23 constituted the “entire unpaid balance” due and waived all claims relating to the project.

“[A] release that, by its terms, extinguishes liability on any and all claims arising in connection with specified matters is deemed to encompass claims of fraud relating to those matters, even if the release does not specifically refer to fraud and was not granted in settlement of an actually asserted fraud claim.