Shive v. 24 Hour Fitness

2025 COA 87
CourtColorado Court of Appeals
DecidedNovember 6, 2025
Docket24CA2075
StatusPublished

This text of 2025 COA 87 (Shive v. 24 Hour Fitness) is published on Counsel Stack Legal Research, covering Colorado Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Shive v. 24 Hour Fitness, 2025 COA 87 (Colo. Ct. App. 2025).

Opinion

The summaries of the Colorado Court of Appeals published opinions constitute no part of the opinion of the division but have been prepared by the division for the convenience of the reader. The summaries may not be cited or relied upon as they are not the official language of the division. Any discrepancy between the language in the summary and in the opinion should be resolved in favor of the language in the opinion.

SUMMARY November 6, 2025

2025COA87

No. 24CA2075, Shive v. 24 Hour Fitness — Contracts — Colorado Premises Liability Act — Exculpatory Clauses — Clear and Unambiguous Intent to Extinguish Liability

A division of the court of appeals concludes that the references

to “facilities” in the exculpatory clause of a health club membership

agreement do not express the parties’ intention to extinguish the

club’s liability for claims arising from a member’s slip and fall on an

icy, publicly accessible sidewalk near the entrance to one of the

club’s buildings. For this reason, the division reverses the district

court’s grant of summary judgment to the club on the injured club

member’s Premises Liability Act claim. COLORADO COURT OF APPEALS 2025COA87

Court of Appeals No. 24CA2075 City and County of Denver District Court No. 23CV33224 Honorable J. Eric Elliff, Judge

Matthew Shive,

Plaintiff-Appellant,

v.

24 Hour Fitness USA, LLC,

Defendant-Appellee.

JUDGMENT REVERSED AND CASE REMANDED WITH DIRECTIONS

Division III Opinion by JUDGE LIPINSKY Román, C.J., and Kuhn, J., concur

Announced November 6, 2025

Robinson & Henry, P.C., Matthew W. Hamblin, Jon M. Topolewski, Denver, Colorado, for Plaintiff-Appellant

Dietze and Davis, P.C., William A. Rogers, III, Nathan A. Klotz, Christina M. Gonsalves, Lauren N. Davis, Boulder, Colorado, for Defendant-Appellee

Dormer Harpring, Timothy M. Garvey, Denver, Colorado; Sliger Law Firm, Amber Sliger, Colorado Springs, Colorado, for Amicus Curiae Colorado Trial Lawyers Association ¶1 Through exculpatory agreements, parties may seek to insulate

themselves from liability arising from their negligent acts. See

Miller v. Crested Butte, LLC, 2024 CO 30, ¶ 45, 549 P.3d 228, 237.

Exculpatory agreements implicate “two competing principles:

freedom of contract and responsibility for damages caused by one’s

own negligent acts.” Heil Valley Ranch, Inc. v. Simkin, 784 P.2d

781, 784 (Colo. 1989).

¶2 Although “exculpatory agreements have long been disfavored,”

B & B Livery, Inc. v. Riehl, 960 P.2d 134, 136 (Colo. 1998), and

courts closely scrutinize them, Miller, ¶ 45, 549 P.3d at 237, they

are generally enforceable if they clearly and unambiguously reflect

the parties’ intent to “extinguish liability,” Heil Valley Ranch, 784

P.2d at 785. Courts recognize that competent parties, including

companies that provide services to consumers, have a contractual

right to limit their liability and to allocate business risks in

accordance with their business judgment. See Taylor v. Brooklyn

Boulders, LLC, 2025 IL App (1st) 231912, ¶ 20, 265 N.E.3d 407,

415; see also Core-Mark Midcontinent, Inc. v. Sonitrol Corp., 2012

COA 120, ¶ 13, 300 P.3d 963, 968 (“A limitation of liability

provision is generally enforceable because it represents the parties’

1 bargained-for agreement regarding allocation of risks and costs in

the event of a breach or other failure of the contemplated

transaction.”).

¶3 This appeal examines the limits of when an exculpatory

agreement “clearly and unambiguously” expresses “the intent of the

parties . . . to extinguish liability” in the context of an athletic club

membership agreement. Heil Valley Ranch, 784 P.2d at 785. We

specifically consider whether references to “facilities” in such a

clause bar a club member’s claim under the Premises Liability Act

(PLA), § 13-21-115, C.R.S. 2025, for damages resulting from the

member’s slip and fall on an icy sidewalk near the athletic club’s

entrance.

¶4 Plaintiff, Matthew Shive, appeals the district court’s grant of

summary judgment in favor of defendant, 24 Hour Fitness USA,

LLC, on Shive’s PLA claim. We reverse.

I. Background

A. Facts

¶5 Shive obtained the right to use 24 Hour’s athletic clubs by

signing a preprinted membership agreement containing an

exculpatory clause. The clause says the following:

2 Using [24 Hour’s] facilities involves the risk of injury to you or your guest, whether you or someone else causes it. Specific risks vary from one activity to another and the risks range from minor injuries to major injuries, such as catastrophic injuries including death. In consideration of your use of 24 Hour’s facilities and/or participation in the activities offered by 24 Hour, you understand and voluntarily accept this risk and agree that 24 Hour, its officers, directors, employees, volunteers, agents and independent contractors will not be liable for any injury, or any other damages, to you, your spouse, guests, unborn child, or relatives resulting from the actions or inactions, including negligence, of 24 Hour or anyone on 24 Hour’s behalf or anyone using the facilities, including, without limitation, personal, bodily, or mental injury, or economic loss, whether said use or said injury is related to exercise or not. This Release of Liability includes, without limitation, claims against 24 Hour for negligence, premises liability, and products liability. Further, you understand and acknowledge that 24 Hour does not manufacture fitness or other equipment at its facilities, but purchases and/or leases equipment. You understand and acknowledge that 24 Hour is providing recreational services and may not be held liable for defective products.

¶6 Shive walked out of the club building after working out on a

winter day. Snow and ice had built up on the sidewalk in front of

the building. Shive slipped and fell on ice that had accumulated

3 beneath an awning that extended over the sidewalk near the

building’s front entrance. The fall resulted in a significant injury to

Shive’s knee.

B. Procedural History

¶7 Shive filed a PLA suit against 24 Hour premised on his

allegation that 24 Hour “unreasonably failed to exercise reasonable

care to protect against dangers and/or dangerous activities, of

which [it] actually knew or should have known by failing to remove,

remediate, mitigate and/or properly maintain the dangerous

area/condition.” Shive asserted that 24 Hour had unreasonably

failed to exercise reasonable care by not removing the accumulated

ice near the building’s entrance.

¶8 24 Hour filed a summary judgment motion in which it argued

that the exculpatory clause in Shive’s membership agreement

barred his PLA claim. Shive responded that the exculpatory clause

“cannot be reasonably interpreted to encompass the risk that

[Shive] succumbed to and the location of [his] injury — a fall on ice

outside of the building on an exterior sidewalk as he was leaving

the [club].” He asserted that, “[w]hen read as a whole, [24 Hour]’s

chosen language for its exculpatory provision would suggest a

4 member would be waiving claims based on the inherent risks posed

by the use of a gym or fitness club and the activities one may

participate in at such a facility.” For this reason, Shive said, “the

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2025 COA 87, Counsel Stack Legal Research, https://law.counselstack.com/opinion/shive-v-24-hour-fitness-coloctapp-2025.