U.S. District Court Judge James Curtis Joyner
PHILADELPHIA— A federal judge has granted summary judgment in favor of LA Fitness in a personal injury suit brought against the chain of fitness centers by a man who claimed he was injured at one of its Philadelphia locations, according to a decision filed on April 10 in the U.S. District Court for the Eastern District of Pennsylvania.
U.S. District Judge James Curtis Joyner issued the decision, finding that the man, Tyrone Hill, could not sue the gym for his alleged injuries because his membership contract included a clause that barred him from recovering damages for any injuries caused by the fitness center’s negligence.
"[W]e find that [the] plaintiff understood that he was entering into a written contract which was setting forth the terms and conditions of his membership with LA Fitness, including the fact that he was giving up the right to make any claim(s) against LA Fitness for any loss or damages which he might incur as the result of any active or passive negligence on its part," Joyner said in the order.
In August 2016, Hill claims that he suffered a fractured left leg and other injuries when he allegedly slipped and fell over a yoga mat at a LA Fitness location in Philadelphia, according to the court’s decision. Hill filed suit in March of last year, alleging three counts of negligence against LA Fitness, Federal Realty Management and Fitness International.
The defense counsel then filed a motion for summary judgment in January, arguing that Hill did not have sufficient evidence to support his negligence claims and that his claims were barred by an “exculpatory clause” in his membership agreement.
An exculpatory clause is provision in a contract that allows a party to avoid being held liable if the other party incurs damages during the course of the agreement.
Joyner ruled that exculpatory clauses are valid when they do not contravene public policy, relate entirely to the private affairs of the parties and each party is a free bargaining agent so that the agreement is not a contract of adhesion.
"In this case, [Hill] does not appear to be challenging the validity of the membership agreement's exculpatory clause on the grounds that it is ambiguous, in contravention of public policy or that it is one of adhesion," Joyner wrote in the order. "Rather, [the] plaintiff contends that there is a material issue of fact as to whether he signed the agreement."
Hill testified that the signature at the bottom of the agreement's first page was not his, according the court’s decision. However, that didn’t matter to the judge.
"As is clear from the preceding testimony, while [Hill] may not have signed the first page of the membership agreement, he did read the document and initialed the remaining pages, including the exculpatory clause, which was set forth on the second page of the agreement in a box and in larger typeface from the rest of the document," Joyner wrote in the order.
Hill acknowledged that he read the agreement, initialed its pages and entered into the agreement voluntarily, according to court’s order.
"Seeing no reason to set the said exculpatory clause aside, we shall grant [the] defendants' motion for summary judgment," Joyner wrote in the order.