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Allen vs. L.A. Fitness
Student Name: [Your Name]
Section # [Last 4 Digits]
Wk [Week Number] C.S.: Legal issues Involving Gym Membership Contracts p 313
Facts: Eileen Allen, the plaintiff, joined L.A. Fitness International, LLC, and signed an
agreement for personal training sessions with L.A. Fitness, USA, P.T., LLC, doing business as
Body of Change. Allen alleged that she sustained a shoulder injury while performing an unsafe
exercise directed by a personal trainer who failed to assess her physical condition and needs. She
filed an action against L.A. Fitness to recover damages for simple negligence.
History: The case was initially tried in the Superior Court of New Jersey, Law Division, and
Burlington County, where Allen was awarded $525,000 in damages by a jury that found L.A.
Fitness negligent. L.A. Fitness moved for a directed verdict at the close of Allen's case, citing the
exculpatory clauses in the contract, but the judge denied this motion. L.A. Fitness also filed
motions for judgment notwithstanding the verdict and for a new trial or remittitur, both
dismissed. L.A. Fitness then appealed the decision.
Issue: The legal issue in this case was whether the exculpatory clauses in the personal training
contract, which required Allen to assume the risks associated with her training activities and to
release L.A. Fitness from any related claims, were enforceable under New Jersey law. This
included whether these clauses could transfer the liability for injuries that arose out of the
negligence of its trainers to L.A. Fitness.
Holding: The lower Court, however, did not review the decision, but the appellate Court
declared that provisions of the personal training contract that exempt L.A. Fitness from legal
responsibility were enforceable, thus freeing the establishment of any liability of Allen. The
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Court's decision was influenced by the precedent set in Stelluti v. Casapenn Enterprises, where
the New Jersey Supreme Court upheld similar agreements that limited liability for negligence in
gym activities. Accordingly, the appellate Court opined that the trial court was wrong to have
refused L.A. Fitness's motion to dismiss the case on these provisions. Thus, the judgment of
$525 000 for the settlement of the case in favour of Allen was overturned, and her complaint was
dismissed.
Reasoning: The appellate Court's opinion stemmed from the belief in the legal enforceability of
the clauses Allen excluded from liability through a contract with L.A. Fitness. These clauses
precisely defined that Allen understood and agreed to bear all the risks of the physically active
tasks that she was going to undertake and all the risks resulting from the instructors' negligence.
The Court cited the Stelluti v. Casapenn Enterprises case that laid down this provision to
ascertain whether agreements between the gym and the patrons were legally binding. The MLCP
stated that similar to the Stelluti case, the language in Allen's contract also exculpated L.A.
Fitness from negligence. Also, the Court mentioned that the waiver process was noticeable in
this case, as the risks and the release of liability were clearly explained to Allen.
Result: The appellate Court reversed the lower Court's decision and dismissed Allen's complaint.
This decision reinforced the enforceability of exculpatory clauses in contracts related to gym
activities. It set a precedent that patrons who sign such agreements cannot hold gyms liable for
injuries resulting from negligence if they have explicitly waived such claims.
Johnson V. J. Walter Thompson USA LLC
Student Name: [Your Name]
Section # [Last 4 Digits]
Wk [Week Number] C.S.: Employment Discrimination Under Title VII p. [987]
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Facts: The appeals of three cases involving workers who were purportedly fired because of their
homosexual or transgender identity were combined by the U.S. Supreme Court. These cases
included Aimee Stephens, fired from R.G. & G.R. Harris Funeral Homes in Michigan for
declaring her intention to live as a woman; Donald Zarda, a skydiving instructor in New York,
fired shortly after disclosing his sexual orientation; and Gerald Bostock, dismissed from Clayton
County, Georgia, for playing in a gay recreational softball league. Every team member filed a
lawsuit under Title VII, claiming that there had been illegal sex-based discrimination.
History: Following its first ruling that Title VII does not forbid businesses from terminating
employees for being gay, the U.S. Court of Appeals for the Eleventh Circuit rejected Gerald
Bostock's complaint. The U.S. Court of Appeals for the Second Circuit granted Donald Zarda's
lawsuit, ruling that discrimination based on sexual orientation is illegal under Title VII. The U.S.
Court of Appeals upheld Aimee Stephens's Sixth Circuit case, which maintained that Title VII
prohibits employers from terminating workers according to their gender identity. The appellate
courts disagreed about the extent of Title VII's protections. Therefore, the Supreme Court
granted certiorari to settle the dispute.
Issue: The primary issue was whether Title VII of the Civil Rights Act of 1964, which prohibits
employment discrimination "because of sex," extends to discrimination based on sexual
orientation and transgender status.
Holding: The Supreme Court held that Title VII's prohibition of sex discrimination includes
discrimination based on sexual orientation and transgender status. The Court reasoned that it is
impossible to discriminate against a person for being homosexual or transgender without also
discriminating against that individual based on sex.
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Reasoning: The Court's conclusion was based on the terms' common public understanding at the
time of Title VII's 1964 passage. The Court stated that some actions cannot be taken by
employers "because of" sex, as stipulated by Title VII. It clarified that this includes the
conventional but-for criterion of causation. Therefore, when an employer purposefully terminates
a team member based, in part, on their sexual orientation, they violate Title VII. The Court made
it clear that if the person's sex was one but-for cause, Title VII is activated, regardless of whether
other considerations also played a role in the judgment. The Court used hypothetical situations
where the only distinction between employees is their gender to demonstrate this. It concluded
that firing someone based on sexual orientation or transgender status necessarily involves sex
discrimination.
Result: Following the Supreme Court's ruling, employees who have been subjected to
discrimination based on their sexual orientation or transgender status are now covered under
Title VII safeguards. The Second and Sixth Circuits' rulings, which validated the workers'
claims, were upheld. The verdict of the Eleventh Circuit, which had rejected Bostock's case, was
overturned, and the matter was remanded for additional hearings by the Supreme Court's ruling.
This historic decision confirmed that Title VII's requirements are violated since discrimination of
this kind inevitably entails treating people differently based on their sex.
