Under Minnesota law, release of one alleged tortfeasor will release all others if the settlement agreement manifests such an intent or if the plaintiff received full compensation in law or in fact for damages sought against the remaining tortfeasors. See, e.g., Johnson v. Brown, 401 N.W.2d 85, 88 (Minn.Ct.App. 1987); Somora v. Marriott Corp., 812 F. Supp. 917, 924 (D. Minn. 1993) (citing Luxenburg v. Can-Tex Indus., 257 N.W.2d 804, 807 (Minn. 1977)).

By the plain language of the Mutual Release, Wells Fargo released only Rakish from liability relating to the $35,000 promissory note. Appellants argue the release of Rakish also released the others because Wells Fargo did not execute a Pierringer release, which specifically preserves claims against the remaining defendants and indemnifies the released defendants. "When a settlement agreement does not contain a Pierringer release . . . the general rule is that the `release of one alleged tortfeasor will release all others if the settlement agreement manifests such an intent, or if the plaintiff received full compensation in law or in fact for damages sought against the remaining tortfeasors.'" Johnson v. Brown, 401 N.W.2d 85, 88 (Minn.Ct.App. 1987) (quoting Bixler by Bixler v. J.C. Penney Co., Inc., 376 N.W.2d 209, 214-15 (Minn. 1985)) (emphasis in original).

Under Minnesota law, a non-Pierringer release that does not fully compensate a plaintiff "operates as satisfaction pro tanto as to other tortfeasors." Johnson v. Brown, 401 N.W.2d 85, 88 (Minn. Ct. App. 1987); Gronquist v. Olson, 64 N.W.2d 159, 165 (Minn. 1954) ("Therefore, the amount paid by a tort-feasor to whom the agreement is given will be regarded as a satisfaction Pro tanto as to the other joint tort-feasors.").

This court has noted that "rigid application of this rule has been criticized and ultimately rejected." Johnson v. Brown, 401 N.W.2d 85, 89 (Minn.App. 1987), review denied (Minn. Apr. 23, 1987).

When a settlement agreement does not contain a Pierringer release, the "release of one alleged tortfeasor will release all others only if the settlement agreement manifests such an intent, or if the plaintiff received full compensation in law or in fact for damages sought against the remaining tortfeasors." Johnson v. Brown, 401 N.W.2d 85, 88 (Minn.App. 1987), review denied (Minn. Apr. 23, 1987); see also Bixler by Bixler v. J.C. Penney Co., 376 N.W.2d 209, 214-15 (Minn.

" When parties execute a release agreement that does not result in the plaintiff being fully compensated for the harm she suffered—like the one in this case—the release generally "operates as a satisfaction pro tanto as to other tortfeasors." Johnson v. Brown, 401 N.W.2d 85, 88 (Minn. Ct. App. 1987); see also Gronquist v. Olson, 64 N.W.2d 159, 165 (Minn. 1954). Here, the district court found that Trice's release agreement with Lee and his insurers fell within this general rule, and applied a pro tanto offset to Trice's award in the amount Trice received from Lee and Lee's insurers.

" When parties execute a release agreement that does not result in the plaintiff being fully compensated for the harm she suffered—like the one in this case—the release generally "operates as a satisfaction pro tanto as to other tortfeasors." Johnson v. Brown , 401 N.W.2d 85, 88 (Minn. Ct. App. 1987) ; see also Gronquist v. Olson , 242 Minn. 119, 64 N.W.2d 159, 165 (1954). Here, the district court found that Trice's release agreement with Lee and his insurers fell within this general rule, and applied a pro tanto offset to Trice's award in the amount Trice received from Lee and Lee's insurers.

" When parties execute a release agreement that does not result in the plaintiff being fully compensated for the harm she suffered — like the one in this case — the release generally "operates as a satisfaction pro tanto as to other tortfeasors." Johnson v. Brown, 401 N.W.2d 85, 88 (Minn. Ct. App. 1987); see also Gronquist v. Olson, 242 Minn. 119, 64 N.W.2d 159, 165 (1954). Here, the district court found that Trice's release agreement with Lee and his insurers fell within this general rule, and applied a pro tanto offset to Trice's award in the amount Trice received from Lee and Lee's insurers.

" Id. When a settlement agreement does not contain a Pierringer release, the "release of one alleged tortfeasor will release all others if the settlement agreement manifests such an intent, or if the plaintiff received full compensation in law or in fact for damages sought against the remaining tortfeasors." Johnson v. Brown, 401 N.W.2d 85, 88 (Minn. App. 1987), review denied (Minn. Apr. 23, 1987).

1984). Because a "rigid rule could prevent a plaintiff from being made whole," Johnson v. Brown, 401 N.W.2d 86, 89 (Minn.App. 1987), review denied (Minn. Apr. 23, 1987) the courts will not enforce a general release in favor of a second tortfeasor in the absence of evidence that the release agreement manifests an intention to release all tortfeasors or that the injured party had been fully compensated.