Pruitt v. Strong Style Fitness, 2011 Ohio 5272

Pruitt joined Strong Style Fitness in January 2009, paying for two months of membership and ten personal training sessions.
Upon joining, Pruitt signed a general membership form and a separate Strong Style Rules and Regulations document containing an exculpatory waiver.
The waiver released Strong Style and its agents from any negligence claims, expressly including bodily injury and death arising from gym activities and related medical conditions.
During a fifth training session, Pruitt used an incline leg press under Lyons’s supervision; the machine required a 45-degree seated position and a safety catch to be engaged.
Pruitt pressed 350 pounds; after finishing, he could not visually confirm the safety catch was fully engaged, and the platform allegedly disengaged, causing knee injuries.
Strong Style moved for summary judgment; the trial court granted it, concluding the release was enforceable and Pruitt had no viable negligence claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the exculpatory clause is enforceable	Pruitt argues the clause is unconscionable/ambiguous and against public policy.	Strong Style contends the clause is clear, unambiguous, and enforceable.	Exculpatory clause enforceable; contract terms clear and not unconscionable.
Whether the clause is procedurally or substantively unconscionable	Pruitt contends unequal bargaining power and lack of opportunity to negotiate.	Strong Style asserts terms were clearly presented; Pruitt could have walked away.	Not procedurally or substantively unconscionable; terms were clearly disclosed and understood.
Whether the exculpatory clause bars a negligence claim against Strong Style and Lyons	Pruitt maintains the release does not cover all potential negligent acts or specific trainer conduct.	Release covers negligence by Strong Style and its staff, including trainers.	Yes; the release bars recovery for negligence, including trainer conduct.

Motorists Mut. Ins. Co. v. Jones, 9 Ohio Misc. 113, 223 N.E.2d 381 (Ohio Misc. 1966) (contractual liability waivers evaluated on bargaining position and optional consideration)