This Note provides a history of North Carolina courts' treatment of voluntary settlement agreements prior to Vernon v. Steven L. Mabe Builders. Next, this Note examines the ruling in Vernon, as well as the court's reasoning. The Note then reviews the relevant provisions of the Workers' Compensation Reform Act of 1994 passed by the General Assembly in July, 1994. Finally, the Note addresses the ramifications of the Vernon decision and concludes with a discussion of the decision's effects and the questions it raises.



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