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Earhart v. State3/13/2002
Appeal from the Iowa District Court for Polk County, Robert J. Blink, Judge.
Plaintiff, a student at Iowa State University, appeals from the summary judgment entered in favor of the State in his personal injury action to recover for injuries he sustained in a car accident while returning from a solar car-racing event. AFFIRMED.
Andrew Earhart appeals from the summary judgment entered in favor of the State of Iowa on his personal injury action in which he sought to recover for injuries allegedly sustained in an automobile accident. We conclude the district court correctly determined Earhart contractually released his claims against the State and therefore affirm.
I. Factual Background and Proceedings.
While a student at Iowa State University (ISU) in the College of Engineering in 1997, Andrew Earhart and Karla Abrahamson were members of Team PrISUm, a university-sponsored group which designs, builds, and races solar-powered vehicles at an annual event known as the SunRayce. From April 25 through April 27, 1997, Team PrISUm members drove to Mesa, Arizona, for a qualifying event. The team traveled to the event in two vehicles, a donated Winnebago and an ISU-owned van that towed the team's trailer.
On April 28, team members began their return trip to Ames from Mesa and team members took turns driving the vehicles. At approximately 7:15 a.m. on April 29, team member David Stutzman took his turn driving the van, while Earhart and Abrahamson rested. Around 8:00 a.m., the trailer began swaying from side to side and caused Stutzman to lose control of the van. The van went off the road and struck a fence line.
Earhart and Abrahamson filed a personal injury action in Story County District Court against Stutzman. The district court granted summary judgment in favor of Stutzman concluding (1) Earhart and Abrahamson failed to exhaust their administrative remedies by first filing their claims with the State Appeal Board, and (2) releases signed by Earhart and Abrahamson served to waive their claims.
Earhart and Abrahamson next brought this action in Polk County District Court against ISU, the Board of Regents, and the State of Iowa. ISU and the Board of Regents filed a motion to dismiss, and the plaintiffs voluntarily released them. The State subsequently moved for summary judgment, contending plaintiffs had contractually released the State from liability for their injuries. The district court granted the motion, concluding the voluntarily signed releases unambiguously waived all claims relating generally to the plaintiffs' participation in Team PrISUm activities. Earhart appeals from this ruling.
II. Standard of Review.
This court reviews summary judgment rulings for correction of errors of law. Iowa R. App. P. 6.4. When the facts pertinent to the issues raised in the summary judgment motion are undisputed, our only task on appeal is to decide whether the district court correctly applied the law when it granted the defendants' motion. Sanford v. Manternach, 601 N.W.2d 360, 363 (Iowa 1999).
III. The Releases.
Team members were required to sign two different release and waiver of liability documents. The first release, which Earhart signed at one of the first Team PrISUm meetings during the 1996-97 school year, provides in pertinent part as follows:
This affects any rights you may have if you are injured or otherwise suffer damages while participating in any activity in conjunction with activities sponsored by Team PrISUm.
I, (name) hereby release, waive, discharge and covenant not to sue Team PrISUm, the State of Iowa, the Board of Regents of the Sta
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