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Keywords

contractdefendantnegligenceliabilitytrialleasesustained

defendantnegligenceliabilitytrialleasecorporationsustained

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Seigneur v. National Fitness Institute, Inc., 132 Md.App. 271, 752 A.2d 631

Facts

On September 4, 1998, Gerilynne Seigneur and her husband filed a complaint against NFI, claiming that Ms. Seigneur was injured due to NFI's negligence during an initial evaluation at the fitness club. NFI argued that the exculpatory clause in the Participation Agreement, which Ms. Seigneur signed, released them from liability for injuries caused by their negligence. The clause stated that all exercises were undertaken at the member's sole risk and released NFI from all claims arising from the use of their services and facilities.

On September 4, 1998, Gerilynne Seigneur and her husband James filed a complaint in the Circuit Court for Montgomery County against National Fitness Institute, Inc. (“NFI”). The Seigneurs asserted that Ms. Seigneur was injured as a result of NFI's negligence while she was undergoing an initial evaluation at a fitness club owned and operated by NFI.

Issue

Does the exculpatory clause in the agreement entered into by the parties validly release NFI from all liability for injuries to Ms. Seigneur caused by NFI's negligence?

Rule

An exculpatory clause is valid and enforceable if it clearly and specifically indicates the intent to release the defendant from liability for personal injury caused by the defendant's negligence.

Analysis

The court examined the exculpatory clause in the Participation Agreement and found that it unambiguously released NFI from liability for all acts of negligence. The clause explicitly stated that Ms. Seigneur released NFI from all claims, including those arising from active or passive negligence. The court determined that the clause was not a contract of adhesion that would invalidate its enforceability, as Ms. Seigneur had multiple options for fitness services and was aware of the clause prior to her injury.

The court examined the exculpatory clause in the Participation Agreement and found that it unambiguously released NFI from liability for all acts of negligence.

Conclusion

The court affirmed the trial court's ruling that NFI's exculpatory clause is enforceable, thereby releasing NFI from liability for the injuries Ms. Seigneur sustained while on its premises.

The court affirmed the trial court's ruling that NFI's exculpatory clause is enforceable so as to release NFI from liability for injuries Ms. Seigneur sustained while on its premises.

Who won?

National Fitness Institute, Inc. prevailed in the case because the court upheld the validity of the exculpatory clause in the membership agreement, which effectively released them from liability for negligence.

NFI is a Maryland corporation operating an exercise and fitness facility on Shady Grove Road in Rockville, Montgomery County, Maryland.

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