Alfone release

An Alfone release is a waiver by a personal injury claimant of any possible future wrongful death action arising from the injuries which are the basis of personal injury claim. In Alfone v. Sarno, 87 N.J. 99 (1981), the Supreme Court ruled that mere settlement or judgment for damages in a personal injury action did not bar a future claim for wrongful death arising from same injuries (although a judgment of no cause for action would be a bar). The court suggested that a claimant could specifically release a future wrongful death claim. The enforcement of such a release was upheld in Garde v. Wasson, 251 N.J. Super. 608 (App. Div. 1991), certif. den., 127 N.J. 560 (1992).