Ramirez v. Fair Grounds Corp.
575 So. 2d 811, 1991 WL 32180, 1991 La. LEXIS 646 (1991)
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Rule of Law:
Under Louisiana Civil Code Article 2004, any contractual clause that, in advance, purports to exclude or limit one party's liability for causing physical injury to the other party is null and void.
Facts:
- Henry Ramirez was a licensed racehorse trainer with over 25 years of experience.
- On September 30, 1984, Ramirez signed an application for stall space at the facility owned by the Fair Grounds Corporation.
- The application contained clauses stating that Fair Grounds would not be liable for any injury to Ramirez, even if caused by the condition of the premises or Fair Grounds' own negligence.
- On February 10, 1985, approximately four months after signing the application, Ramirez fell from a 12-foot high loft in a stall at the Fair Grounds.
- Ramirez alleged the fall was caused by the lack of a handrail or bannister on the loft.
- As a result of the fall, Ramirez suffered severe, permanently disabling physical injuries to both of his feet and legs.
Procedural Posture:
- Henry Ramirez filed suit against the Fair Grounds Corporation in the trial court, alleging strict liability for his injuries.
- Fair Grounds filed a motion for summary judgment, arguing that the release clauses in the stall application barred Ramirez's suit.
- The trial court granted Fair Grounds' motion for summary judgment and dismissed Ramirez's suit.
- Ramirez, as appellant, appealed the decision to the Louisiana Court of Appeal, Fourth Circuit.
- The court of appeal affirmed the trial court's judgment in favor of Fair Grounds, the appellee.
- The Supreme Court of Louisiana granted Ramirez's writ application to review the court of appeal's decision.
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Issue:
Does a pre-injury contractual clause that releases a party from all liability for causing physical injury to the other party violate Louisiana Civil Code Article 2004 and is therefore null and void?
Opinions:
Majority - Dennis, Justice
Yes. A pre-injury contractual clause that releases a party from liability for causing physical injury is null and void. The plain language of Louisiana Civil Code Article 2004 is clear and unambiguous in stating, 'Any clause is null that, in advance, excludes or limits the liability of one party for causing physical injury to the other party.' The release and indemnity clauses in the stall-space application signed by Ramirez fall directly within this statutory prohibition. The defendant's argument that legislative comments to the statute should alter its plain meaning is unpersuasive, as the legislative act itself explicitly provides that the comments are not part of the law. Because the statutory text is clear and its application does not lead to absurd consequences, the court must apply it as written without resorting to extrinsic interpretive aids.
Analysis:
This decision strictly interprets Louisiana Civil Code Article 2004, establishing that parties cannot contractually waive their right to recover damages for future physical injuries caused by another's fault. It reinforces the principle of plain meaning in statutory construction, prioritizing the clear text of a law over any potentially conflicting official comments. This ruling significantly limits the enforceability of broad exculpatory and indemnity clauses in contracts involving activities with a risk of physical harm, ensuring that property owners and service providers in Louisiana remain liable for their negligence that results in physical injury.
