Background
Stephanie Walker, an elderly widow with limited income, suffered a sewage backup in her Charlotte home that rendered it uninhabitable. The City of Charlotte offered a settlement of forty-five thousand dollars contingent on a release of all claims. Walker signed the release after initially protesting and writing that she was homeless with no other choice, later removing the protest statement at the City’s request. She subsequently sued, alleging the release was signed under undue influence, but the district court granted summary judgment to the City.
The court’s reasoning
The Fourth Circuit reviewed the case de novo under North Carolina law, which allows a contract to be set aside if obtained through undue influence. The court found that Walker presented forecast evidence sufficient for a jury to conclude undue influence existed. Factors included Walker’s age, economic condition, and emergency situation, the City’s knowledge of her distress, and the disparity between the settlement amount and her actual damages. The court noted that while Walker had counsel, the record showed her counsel could not aid in negotiations, and the City conditioned rescue funds on the release of claims arising from the City’s alleged negligence.
Because Walker has forecast evidence from which a jury could conclude that the release was obtained through undue influence, we reverse the district court’s grant of summary judgment to the City of Charlotte.
Walker v. City of Charlotte, No. 25-1334, slip op. at 2 (4th Cir. Apr. 8, 2026)
The dissent
One party’s personal financial condition is not sufficient to show that the other party in any way overbore the first party’s will.
NIEMEYER
What it means going forward
The decision remands the case for further proceedings, allowing Walker to proceed with discovery on her negligence and other claims after a jury determines whether the release was voidable due to undue influence.