This decision holds that Civil Code 1668 does not bar enforcement of a release as to fraud or statutory violation claims that arose before the release was signed but does bar enforcement of a release as to such claims if any element of the complete tort (such as reliance or damages) still remains unsatisfied at the time the release is signed.

California Court of Appeal, Second District, Division 2 (Ashmann-Gerst, Acting P.J.); November 15, 2018;  29 Cal. App. 5th 146