Release of Liability Contained in Event Entry Form Held to Apply To a Subsequently Added Event Sponsor

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On any given week, most of us are asked to sign at least one or two releases of liability for various sporting and recreational events. The Missouri Court of Appeals for the Eastern District recently held those releases may be effective as to entities who were not releasees at the time the releasor signed the document.

On May 12, 2009, Plaintiff Colleen Holmes executed an entry form for the 2009 Susan G. Komen Race for the Cure to be held on June 13, 2009. The form included a section titled "Race Waiver and Release" which contained the following language as to the individuals and entities to be release: "The St. Louis Affiliate of Susan G. Komen for the Cure, their affiliates, and any affiliated individuals, any Event sponsors and their agents and employees, and all other persons or entities associated with this Event..."

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