Wednesday, January 1, 2014

Stelluti v. Casapenn Enterprises, LLC case brief

Stelluti v. Casapenn Enterprises, LLC case brief summary
1 A.3d 678 (2010)

The Court granted certification to plaintiff member, allowing her to appeal the judgment of the Superior Court, Appellate Division (New Jersey), which affirmed a trial court's grant of summary judgment in favor of defendant fitness club. The member had brought a negligence suit against the fitness center after she was allegedly injured when the bike she was riding malfunctioned.

While participating in a bicycle spinning class, the adjustable handlebars dislodged from the member's bike and she fell forward while her feet remained strapped to the pedals, and she incurred various injuries. The member asserted negligence against the fitness center in failing to maintain and set up the bike, failing to properly instruct her on its use, failing to provide warnings and safe equipment, and other claims. The fitness center filed a motion for summary judgment based on the waiver of liability agreement that the member signed.

The trial court granted the motion, finding that the agreement was enforceable because the fitness center was not subject to a requirement to perform under a specific duty imposed by law, the waiver was not unconscionable, and covered claims sounding in both negligence and gross negligence. 


  • The Appellate Division affirmed, finding that the agreement was not unconscionable and, thus, valid. 
  • The Court agreed, holding that it was not contrary to the public interest, or to a legal duty owed, to enforce the pre-injury waiver of liability agreement that the member entered into with the fitness center.

The Court affirmed the judgment of the Appellate Division that sustained the summary judgment award to the fitness center.

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