Court upholds hold harmless agreement executed by volunteer employee

Patricia Brown was injured in a fall at the Northwoods Animal Shelter.  She attempted to sue, however, the shelter's insurer sought dismissal of her claim, relying on the hold harmless agreement she was required to sign before beginning work as a volunteer.  Brown's attorneys argued that the hold harmless agreement or "release" was not valid because such an agreement requires consideration and she did not receive any.  The Court dismissed this argument and held that allowing Brown to work with the animals was adequate consideration for her waiver of rights.