Brendan Van Voris and Josephine Durkin v. Team Chop Shop, LLC D/B/A Chop Shop MMA Jerry Howell
Brendan Van Voris and his wife, Josephine Durkin, appealed a trial court's summary judgment dismissing their negligence and gross negligence claims against Team Chop Shop, LLC d/b/a Chop Shop MMA and Jerry Howell. The claims arose from an injury Van Voris sustained during an aikido course after signing a pre-injury release. The appellate court affirmed the summary judgment on the negligence claims, finding the release met fair notice requirements. However, it reversed the summary judgment on the gross negligence claims, stating that pre-injury releases for gross negligence are against public policy and that such claims are not legally inseparable from negligence for the purpose of such a release. The case was remanded for further proceedings concerning the gross negligence claims.