The FELA (45 U.S.C. § 55) invalidates any contractual provision “the purpose or intent of which shall be to enable any common carrier to exempt itself from any liability created by this act [FELA].” However, a release provided in settlement of a specific liability claim is enforceable. (See Callen v. Pennsylvania R. Co. (1948) 332 U.S. 625, 631.) Federal courts are divided about whether a release given in settlement of a specific injury is enforceable if it extends to other, unknown injuries. This decision holds that the release that plaintiff gave in settlement of his previous injury claim was not enforceable insofar as it purported to extend to future claims unrelated to the particular injury that was being settled.