In Dalury v. S-K-I, Ltd., 164 Vt. 329, 670 A.2d 795 (1995), a negligence action brought by an injured skier against the operator of a ski area, we held that a ski area operator may not, through an exculpatory agreement printed on a season pass and photo identification card, be held harmless for injuries to its patrons resulting from its own negligence. 164 Vt. at 330, 670 A.2d at 796. The Court identified that circumstance as requiring a public policy based exception to upholding the validity of exculpatory agreements, with the principal public policy implications being those "underlying the law of premises liability." Id. at 334, 670 A.2d at 799.