Jeanne Anderson v. Rugged Races, LLC, No. 20-3436 (8th Cir. 2022)
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Plaintiff shattered her heel bone participating in the Rugged Maniac Twin Cities 5k obstacle race at the Wild Mountain Recreation Area (“Wild Mountain”). Plaintiff sued Rugged Races LLC (“Rugged Races”), the race promoter and the owner of Wild Mountain, alleging that Defendants were “grossly negligent” in failing to perform their duties to protect race participants from unreasonable risks of harm.
Plaintiff appealed the district court’s grant of summary judgment in favor of both Defendants. On appeal, Plaintiff argues (i) the exculpatory clause is unenforceable; (ii) if enforceable, it does not waive claims based on Defendants’ alleged greater-than-ordinary negligence; and (iii) the summary judgment record includes evidence from which a reasonable jury could find greater-than-ordinary negligence.
The Eighth Circuit affirmed. The court explained that under Minnesota law, as in most States, “ordinary negligence” is the “failure to exercise such care as persons of ordinary prudence usually exercise under such circumstances.” The court wrote that it agrees with the district court that “[t]he fact that thousands of participants -- many of whom undoubtedly outweighed Plaintiff-- jumped into the landing pit without incident is compelling evidence that the water level was not unreasonably low.” Further, the court agreed with the district court that Plaintiff offered “little more than speculation” supporting her contentions that the rock was present before the pit was filled and would have been discovered had the construction crew not acted with greater-than-ordinary negligence. As such, Plaintiff’s negligence claims were waived by the valid and enforceable exculpatory clause in the Race Participant Agreement.
Court Description: [Loken, Author, with Colloton and Shepherd, Circuit Judges] Civil case - Personal injury. The exculpatory clause in the pre-race agreement plaintiff signed in order to participate in the Rugged Maniac Twin Cities 5K waived plaintiff's ordinary negligence claims; the waiver was limited to claims of ordinary negligence; plaintiff failed to show that defendants acted with greater-than-ordinary negligence during or after the race, and the district court did not err in granting defendants' motion for summary judgment.
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