## Facts

- Will Wright, a Virginia resident, auditioned in Washington, D.C. to appear as a contestant on *Wheel of Fortune* and was selected to participate.
- On the day of taping in Washington, D.C., Wright signed a contestant release containing a capitalized waiver of “any claims” against Sony for “injury or damage” resulting from participation in the program.
- After Wright won the episode, the host embraced him and jumped up and down in celebration.
- Wright later reported lower-back pain and attributed the injury to the post-win celebration.
- Wright sued Sony asserting negligence and intentional infliction of emotional distress (IIED).
- Sony moved for summary judgment, arguing the signed release barred both claims.

## Issues

1. Whether District of Columbia law or Virginia law governed the enforceability of the contestant release.
2. Whether, under the applicable law, the release was valid and enforceable as a prospective waiver of liability.
3. Whether the waiver language clearly and unambiguously covered personal-injury claims arising from participation in the show.
4. Whether the release barred Wright’s negligence and IIED claims as a matter of law on summary judgment.

## Decision

- The court applied District of Columbia choice-of-law rules and held there was an actual conflict: Virginia generally prohibits pre-injury releases, while D.C. often enforces them if clear and not contrary to public policy.
- The court concluded D.C. had the more significant relationship to the dispute because the auditions, taping, and alleged injury occurred in Washington, D.C.
- Applying D.C. law, the court held the release was enforceable and not void on public-policy grounds in the context of voluntary participation in an entertainment program.
- The court held the waiver was conspicuous and unambiguous and encompassed “any claims” for “injury or damage” caused by participation.
- The court granted Sony’s motion for summary judgment, holding the release barred Wright’s negligence claim and his IIED claim.

## Legal Principles

- In the District of Columbia, prospective exculpatory clauses may be enforced when they do not violate public policy and clearly express an intent to waive the liability at issue.
- Under D.C. choice-of-law doctrine, courts determine whether a true conflict exists and then apply a governmental-interest/significant-relationship analysis to select the governing law.
- A liability waiver must be clear, unequivocal, and unambiguous; conspicuous presentation supports enforceability.
- A broadly worded waiver covering “any claims” for injury arising from participation can bar tort claims based on ordinary negligence connected to that participation.
- Even where a plaintiff pleads IIED, summary judgment is appropriate when the claim is within the scope of an enforceable release and the record does not support the required level of extreme and outrageous conduct.

## Conclusion

The court applied District of Columbia law and enforced the contestant release as a clear and conspicuous pre-injury waiver, which barred the contestant’s negligence and IIED claims arising from an injury allegedly sustained during the game show’s post-win celebration, warranting summary judgment for Sony.


Wright v. Sony Pictures Ent. Inc., 394 F. Supp. 2d 27 (D.D.C. 2005)