Short v. CircusTrix Holdings

CourtCourt of Appeals of North Carolina
DecidedNovember 17, 2020
Docket20-285
StatusPublished

This text of Short v. CircusTrix Holdings (Short v. CircusTrix Holdings) is published on Counsel Stack Legal Research, covering Court of Appeals of North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Short v. CircusTrix Holdings, (N.C. Ct. App. 2020).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA20-285

Filed: 17 November 2020

Buncombe County, No. 19 CVS 365

CHARLES J. SHORT, Plaintiff

v.

CIRCUS TRIX HOLDINGS, LLC; SKY ZONE LLC; SKY ZONE FRANCHISE GROUP, LLC; SKYZONE ASHEVILLE, LLC d/b/a SKYZONE TRAMPOLINE PARK; AND JOHN DOES 1-3, Defendants

Appeal by Defendants from an Order entered 13 September 2019 by Judge

Marvin P. Pope in Buncombe County Superior Court. Heard in the Court of Appeals

20 October 2020.

Davis Law Group, P.A., by Brian F. Davis, for plaintiff-appellee.

Cranfill Sumner & Hartzog, LLP, by John W. Ong, Meredith F. Hamilton, and Steven A. Bader, for defendants-appellants.

HAMPSON, Judge.

Factual and Procedural Background

Circus Trix Holdings, LLC, Sky Zone, LLC, Sky Zone Franchise Group, LLC,

and Sky Zone Asheville, LLC d/b/a Sky Zone Trampoline Park (collectively,

Defendants) appeal from the trial court’s 13 September 2019 Order denying

Defendants’ Motion to Compel Arbitration where the trial court ruled there was no SHORT V. CIRCUS TRIX HOLDINGS, LLC

Opinion of the Court

valid agreement to arbitrate between the parties. The Record before us tends to show

the following:

On 4 April 2019, Charles J. Short (Plaintiff) filed a First Amended Complaint1

(Complaint) asserting Defendants violated North Carolina’s Device Safety Act and

were negligent in connection with injuries Plaintiff sustained while visiting

Defendants’ trampoline park in Asheville, North Carolina. Plaintiff alleged on or

about 27 January 2018, Plaintiff and his wife decided to celebrate their daughter’s

birthday at Sky Zone Asheville trampoline park. On or about that same date,

Plaintiff’s wife visited Sky Zone Asheville’s website to book the party. As part of the

online booking process, Plaintiff’s wife filled out and signed liability waivers for

Plaintiff and the couple’s three children. Plaintiff further alleged, at no time prior to

the incident in question, did Plaintiff know about his wife’s signing a waiver, nor did

he authorize her to do so. The Complaint further alleged, upon arrival at Sky Zone

Asheville, Plaintiff and his group were “checked in” by a manager, then the group

removed and stowed their shoes.

Plaintiff asserted he then began to “look around the facility to see what other

activities were offered” before making his way to the “free climb” wall. Plaintiff

claimed he asked the attendant for direction on “what to do” and the attendant

responded “just climb the wall and jump into the foam pit. Keep your feet apart when

1 Plaintiff filed an earlier Complaint on 25 January 2019 alleging Defendants’ negligence and

“wanton conduct” caused Plaintiff’s injuries.

-2- SHORT V. CIRCUS TRIX HOLDINGS, LLC

you jump.” Plaintiff then climbed the wall and, before jumping off, asked the

attendant: “And I can just jump off?” The attendant responded, “jump away from the

wall, land feet first. Go ahead and jump.” Plaintiff claimed he did as the attendant

instructed, and when he entered the pit and his feet impacted the floor, he fractured

both his right and left tibias.

On 16 July 2019, Defendants filed their Motions to Dismiss and Answer to

Plaintiff’s First Amended Complaint (Answer). In their Answer, Defendants alleged

“Plaintiff signed a Participant Agreement, Release and Assumption of Risk with Sky

Zone . . . contain[ing] an arbitration provision which is specifically highlighted by

requesting that the signor place an ‘X’ acknowledging that he/she read the clause.”

Defendants also argued the trial court lacked subject-matter jurisdiction based on the

signed agreement containing the arbitration clause. Defendants admitted all

customers are required to read and sign a “Participation Agreement, Release and

Assumption of Risk” (Agreement) online or at the facility prior to being allowed to use

Sky Zone Asheville’s facilities and equipment. Defendants also admitted an

Agreement “was signed by or for Plaintiff[.]” Defendants further raised a number of

affirmative defenses including: Release and Waiver; Arbitration, as set forth in the

Agreement; and Contractual Limitations.

Also on 16 July 2019, Defendants filed a Motion to Compel Arbitration and

Stay Proceedings (Arbitration Motion). Defendants attached an Affidavit of Sky Zone

-3- SHORT V. CIRCUS TRIX HOLDINGS, LLC

(Defendants’ Affidavit)—completed by Sky Zone Asheville General Manager Travis

Wilson Fowler—and a copy of the Agreement purportedly signed by Plaintiff.

Defendants alleged Plaintiff “electronically signed the agreement for himself” and

“entered into the Agreement in consideration of Plaintiff being allowed to use the Sky

Zone Asheville facilities and equipment . . . .” The Agreement’s arbitration clause

states:

I understand that by agreeing to arbitrate any dispute . . . I am waiving my right, and the right(s) of the minor child(ren) above, to maintain a lawsuit against [Defendants] . . . for any and all claims covered by this Agreement. By agreeing to arbitrate, I understand that I will NOT have the right to have my claim determined by a jury . . . .

In Defendants’ Affidavit, Travis Fowler stated he became the general manager

in January 2018 and was the general manager at the time Plaintiff was injured.

Fowler then explained Sky Zone Asheville’s policies and procedures regarding

Participation Agreements and customers using Sky Zone Asheville’s facilities.

Fowler stated all participants must sign an Agreement before entering and using the

facilities. In addition, “all participants had to check in and be provided with a

temporary sticker” in order to confirm they “had signed and acknowledged the

Agreement.” According to Fowler, temporary stickers were not “provided to those

individuals who had not executed the Agreement, either online or in person.”

Fowler stated Sky Zone Asheville’s “online system for the execution of the

Agreement” recorded information about the participant and this information “was

-4- SHORT V. CIRCUS TRIX HOLDINGS, LLC

then used when the participant arrived in order to confirm their execution of the

agreement.” Fowler also asserted, on the day of Plaintiff’s injury, Plaintiff would

have been asked if [he] had completed the Agreement online.” Those who had not

completed the agreement online would have been directed to a “Waiver Station Kiosk”

where they would complete the Agreement and receive a receipt. A participant would

then take this receipt to the check-in counter where the participant would buy a ticket

and receive a temporary sticker. Participants who advise they completed the

Agreement online are directed to the check-in counter where a Sky Zone Asheville

employee checks the online system to confirm completed Agreements before

participants buy a ticket and receive a sticker. Moreover, Fowler stated in January

2018, there were Guest Responsibility signs placed throughout the facility advising

participants they were required to execute the Agreement and of other warnings.

On 28 August 2019, Plaintiff filed a Response to Defendants’ Motion to Compel

Arbitration and Stay Proceedings (Response). In this Response, Plaintiff asserted he

did not sign the Agreement; Plaintiff’s wife signed the Agreement for him without

Plaintiff’s “permission or authorization;” at no time “before, during, or after his

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Bluebook (online)
Short v. CircusTrix Holdings, Counsel Stack Legal Research, https://law.counselstack.com/opinion/short-v-circustrix-holdings-ncctapp-2020.