In Doyle v. Bowdoin College, 403 A.2d 1206 (Me. 1979), one of the defendants was Bowdoin College, a private educational institution.
In that case, however, the Supreme Judicial Court of Maine interpreted the putative releases as being ambiguous and, hence, unenforceable, id. at 1208, and the Maine court stated that it had "no occasion to reach the further issue whether contractual provisions which relieve a party from liability for that party's own negligence would be unenforceable and void as contravening public policy." Id. at 1207 n.2.