In Mairo v. Yellow Cab Co. (1929) 208 Cal. 350, the California Supreme Court reviewed a directed verdict in the defendant's favor, where the trial court concluded that the plaintiff had waived his rights by executing several releases. (Id. at pp. 351-352.) The plaintiff was an illiterate Russian immigrant who understood little spoken English. (Id. at p. 351.) He was injured after being hit by the defendant's taxicab and during the course of his medical treatment, the defendant had him sign several releases in exchange for the payment of his medical treatment. (Id. at pp. 351-352.) The plaintiff asserted that the defendant misrepresented the true contents of the releases and that he believed they were merely a permit to operate on him and receipts. (Id. at p. 352.) The court held that if the true nature of the releases was "misrepresented to the plaintiff so that he did not know what he was really signing, they are, of course, void. But under the conflicting evidence here it is impossible to tell whether such was the fact. This also was an issue which should have gone to the jury and it was, therefore, erroneous for the trial court to direct said verdict for defendant." (Ibid.)