Hohe v. San Diego Unified Sch. Dist

In Hohe v. San Diego Unified Sch. Dist (1990) 224 Cal. App. 3d 1559, a high school student was injured during a school hypnotism show. She and her father had both signed releases but the releases did not contain the word negligence or specifically address that subject and the scope of the waivers of liability were ambiguous. Therefore, the Hohe court refused to apply the doctrine of express assumption of risk. ( Id. at p. 1567.)