In Zivich v. Mentor Soccer Club, Inc., 82 Ohio St. 3d 367, 696 N.E.2d 201 (1998), a seven-year-old child was enrolled in a non-profit soccer club. The child's mother executed an exculpatory agreement releasing the club from liability for any claims by the child. The Zivich court determined that the issue involved a determination of whether Ohio public policy justified enforcement of the exculpatory agreement. In determining that the agreement was enforceable, the court examined pertinent statutory and case law in making its public policy decision. The court also reviewed case law discussing the importance of parental interest in the care, custody, and management of their children. Finally, the court noted with approval the distinction between pre-injury and post-injury releases. See Zivich v. Mentor Soccer Club, Inc., supra.