Fitness Center Injury - Release Agreement in California

In Benedek v. PLC Santa Monica (2002) 104 Cal.App.4th 1351, a health club member sustained injuries while adjusting an overhead television in preparation for using an elliptical exercise machine. An agreement was signed by the plaintiff, releasing the health club owners from liability for injuries sustained while in the spa, whether the injuries were sustained during the use of exercise equipment or not. (Id. at p. 1354.) The Benedek court held that the release barred recovery. (Ibid.) The release provided that the waiver was intended to be a complete release of any responsibility for personal injuries sustained by the plaintiff while on the health club's premises, whether using the exercise equipment or not. (Benedek, supra, 104 Cal.App.4th at p. 1354.) The court determined, based in part upon another provision in the plaintiff's agreement, that the purpose for which the release was given was to allow the plaintiff access to the health club's facilities. (Id. at p. 1358.) The court concluded that plaintiff's injuries were reasonably related to the purpose of the release, to allow plaintiff access to and use of the facilities.