During the first two weeks of December 2008, the appellate courts in Florida decided two cases that are favorable to plaintiffs and people injured as a result of negligence. The first case was decided by the state Supreme Court and is entitled Kirton v. Fields. In that case, the court determined that a release signed by a parent, before an injury, may not be enforceable against the operator of a commercial activity. In this particular case, the release signed by the minor’s father so that the minor could gain access to a motorcross sports park to ride his ATV was held unenforceable because it prevented the minor’s estate from bringing a cause of action against the commercial establishment that provided the activity which resulted in the minor’s death.