How have courts interpreted the words of the release clause in a release agreement?

The District would have us apply the opposite rule, found in Neverkovec v. Fredericks (1999) 74 Cal.App.4th 337 (Neverkovec) and its progeny. That case concluded that third parties are not empowered to "'enforce covenants made not for [their] benefit,'" and that a third party's right to enforce performance "'is predicated on the contracting parties' intent to benefit him.'" (Id. at p. 348) Thus, essentially, the words of a release alone are insufficient, and the parties' intent must be probed, by the use of extrinsic evidence, to show actual intent to release. (Id. at p. 349.)

This reasoning was rejected quite recently by Rodriguez v. Oto (2013) 212 Cal.App.4th 1020 (Rodriguez). The court stated that it had "grave reservations about the reliability of the above passage as a statement of the law applicable to a case where, as here, the contract expresses unambiguously an intent to confer rights on a class of persons including the third party asserting rights under the contract. The gravamen of the passage appears to be that even where the contract plainly expresses an intent to grant rights to the party claiming them, he can only establish those rights by presenting extrinsic evidence sufficient to show that the parties really meant what they said. Such an approach flies in the face of 'the generally applicable law of contracts' [citation]which, as we have said, determines the parties' intent in the first instance from what they said, and moves on to other evidence only if some recognized ground is shown to do so, such as ambiguity, fraud, mistake, or unconscionability." (Id. at p. 1030.)

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