I agree with the majority that the release plaintiff executed pertained not only to her claims in the workers’ compensation proceeding but also to any civil claims she may have had against her employer. There is one point, however, on which I wish to comment.
According to the majority, standardized language in the release stating that the employee is giving up “ ‘all claims and causes of action’ relating to the injury” (maj. opn., ante, at p. 305) is sufficient to put any employee on notice that the release covers not only workers’ compensation claims but also any potential claims the employee could assert against the employer in a civil lawsuit. To conclude otherwise, the majority says, would unduly burden employers because they “would have to struggle to enumerate all claims the employee might plan to allege.” (Maj. opn., ante, at p. 306.) I do not share that view.
Although here the preprinted release form’s language, considered together with the evidence presented, shows there was no misunderstanding on plaintiffs part that she was giving up all of her workers’ compensation claims and also those she could have brought in a civil action under the Fair Employment and Housing Act, that may not always be true. Workers’ *311compensation proceedings are generally informal. And unlike plaintiff here, not every injured worker is represented by counsel. To ensure an employee’s understanding that any preprinted release form executed as part of a settlement with the employer covers workers’ compensations claims as well as any potential claims that could be brought in a civil lawsuit against the employer based on the same events leading to the injury, the form should say so not in obscure legal jargon but in clear and simple language. (Putting such language in bold letters would highlight its importance.) The proposed language, in my view, would be clearer than simply stating that the release form covers “all claims and causes of action.” The added clarity would render it unnecessary to burden the employer with “enumerat[ing] all claims the employee might plan to allege,” a concern of the majority. It would also promote fairness for both the injured employee and the employer by decreasing the chances of continuing litigation over what was or was not included in the release.