Copeland v. Healthsouth/Methodist Rehabilitation Hospital, LP
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The Supreme Court reversed the judgment of the court of appeals and vacated the judgment of the trial court in this dispute over the enforceablility of exculpatory provisions of an agreement that released a medical transportation company from liability in transporting a patient to a doctor’s appointment, holding that the exculpatory language in the agreement did not, as a matter of law, bar the patient’s claim in this case.
Before the patient was about to be transported, the medical transportation company’s driver required the patient to sign an agreement releasing the company from liability. After the appointment, the patient fell as he was getting into the company’s van. The patient sued the company, and the company filed a motion to dismiss based on the exculpatory provisions of the agreement. The lower courts held that the exculpatory provisions were enforceable and barred the patient’s claim. The Supreme Court reversed, holding (1) in determining the enforceability of an exculpatory agreement, a court should consider the totality of the circumstances and weigh three non-exclusive factors; (2) as a matter of law, the exculpatory provisions in the agreement at issue were unenforceable and did not bar the patient’s claim against the company.
Court Description:
Authoring Judge: Justice Sharon G. Lee
Trial Court Judge: Judge Rhynette N. Hurd
A rehabilitation hospital hired a medical transportation company to take a patient to a doctor s appointment. Before the transport, the company s driver required the patient to sign an agreement that, in part, released the company from any liability. After the appointment, the patient fell as he was getting into the company s van. He sued the medical transportation company, which moved to dismiss based on the exculpatory provisions of the agreement. The trial court and the Court of Appeals ruled that the exculpatory provisions were enforceable. We hold that to determine the enforceability of an exculpatory agreement, a court should consider the totality of the circumstances and weigh these non-exclusive factors: (1) relative bargaining power of the parties; (2) clarity of the exculpatory language, which should be clear, unambiguous, and unmistakable about what the party who signs the agreement is giving up; and (3) public policy and public interest implications. We hold that the exculpatory provisions in the agreement between the medical transportation company and the patient are unenforceable based on the unequal bargaining power of the parties, the overly broad and unclear language of the agreement, and the important public interest implicated by the agreement. Thus, the exculpatory language in the agreement does not, as a matter of law, bar the patient s claim. We vacate the judgment of the trial court, reverse the judgment of the Court of Appeals, and remand this case to the trial court for further proceedings.
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