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Haines v. St. Charles Speedway, Inc.

United States Court of Appeals for the Eighth Circuit
874 F.2d 572 (1989)


Facts

Since 1952, Norman Haines (plaintiff) was involved in car racing as an owner and spectator. In 1986, Haines entered his race car into a race at a track owned by St. Charles Speedway, Inc. (defendant). Haines was not driving the car but went to the infield to help prepare the car for the race. When entering the infield, Haines signed a release and waiver of liability and indemnity agreement, which St. Charles required all those who entered the infield to sign. The agreement released St. Charles from any and all claims against it arising from Haines’s presence in the infield. Haines previously had signed similar agreements. Haines was struck by his car and injured. He brought suit against St. Charles. St. Charles filed a motion for summary judgment based on the release that Haines had signed. The district court granted the motion. Haines appealed, arguing that he had limited reading ability and was not aware of the document’s significance when he signed it.

Rule of Law

Issue

Holding and Reasoning (Gibson, J.)

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