Are Online Waivers Legal in Missouri?

Missouri has one of the clearest rules in the country on what a release must say, and when a release meets it, the Missouri Supreme Court enforces it. This guide is for Missouri trampoline parks, gyms, climbing walls, riding stables, farms, tour operators and event organizers. It covers electronic signatures, the Missouri test for releases, a 2025 Missouri Supreme Court decision about a trampoline park waiver signed by a parent, and what else a signed agreement does for your business.

This guide is general information about Missouri law, with links to the statutes and cases, so you and your attorney can look into anything that applies to your business.

Waiver Law in Missouri at a Glance

Are Electronic Signatures Legal in Missouri?

Yes. Missouri's UETA, RSMo 432.230, says a record or signature "shall not be denied legal effect or enforceability solely because it is in electronic form," and an electronic signature satisfies a law requiring a signature. The federal ESIGN Act (15 U.S.C. 7001) provides the same baseline nationwide. A waiver signed on a phone, computer or kiosk is signed.

Are Liability Waivers Enforceable in Missouri?

Yes, when they are written the way Missouri courts require. The leading case is Alack v. Vic Tanny International of Missouri, Inc., 923 S.W.2d 330 (Mo. banc 1996). A health club member was hurt on an exercise machine. His contract released the club from "any and all claims," but never mentioned the club's own negligence, and the clause was printed in the same size type as everything else on the back of the form. The Missouri Supreme Court held it did not protect the club and adopted a bright-line test:

• "The words 'negligence' or 'fault' or their equivalents must be used conspicuously so that a clear and unmistakable waiver and shifting of risk occurs."
• "There must be no doubt that a reasonable person agreeing to an exculpatory clause actually understands what future claims he or she is waiving."
• Exculpatory clauses are strictly construed, but they are not against public policy.

When a release meets that test, Missouri courts enforce it. In DeCormier v. Harley-Davidson Motor Co. Group, Inc., 446 S.W.3d 668 (Mo. banc 2014), a student hurt in a motorcycle training course had signed a release of future negligence claims. The Missouri Supreme Court affirmed summary judgment for the course providers, stating that it "will enforce exculpatory agreements to protect a party from liability for their own negligence."

Gross Negligence, Recklessness and Intentional Harm

Alack says "one may never exonerate oneself from future liability for intentional torts or for gross negligence, or for activities involving the public interest." DeCormier adds that Missouri does not recognize degrees of negligence at common law, so a plaintiff cannot get around a valid release just by calling ordinary negligence "gross." The court assumed, without deciding, that a release cannot cover reckless conduct, and found the plaintiff had not shown recklessness.

Waivers for Minors in Missouri

We did not find a Missouri appellate decision squarely deciding whether a parent can release a child's own negligence claim before an injury. The most recent word is Karlin v. UATP Springfield, LLC, No. SC100512 (Mo. banc Mar. 4, 2025). A 17-year-old was hurt on an attraction at a Springfield trampoline park. His mother had signed a release with an arbitration clause on an earlier visit, four months before the injury. He argued she had no authority to sign for him and that the release only covered the day it was signed. The Missouri Supreme Court did not decide either question. Because the agreement had a delegation clause sending disputes about its "scope, arbitrability, or validity" to an arbitrator, the court ordered arbitration and said nothing in its opinion suggests how the arbitrator should rule.

Two details from Karlin stand out. Three of the four releases the park first relied on, including two signed on the day of the injury, were signed by an adult who was not related to the teen and had no authority to sign for him. And the parties disputed whether a release signed on one visit covered a later one. Both are questions about who signed and when, which good records help answer.

A parent's release of their own claims is a separate matter that Karlin did not reach.

More Than a Release

A signed Missouri agreement can do several things besides release negligence claims:

• Arbitration. In Karlin, the waiver's delegation clause sent the dispute, including the question of the mother's authority, to an arbitrator rather than a court. A clause can still be challenged, so its wording is one to review with your attorney.
• Equine and agritourism warnings. RSMo 537.325 and 537.856 require the statutory warning in written contracts, so an agreement that includes it covers that requirement for each participant. The posted signs are required too.
• A record of the warnings. A form listing the activity's risks and your rules, with the guest's acknowledgment, is evidence of what they were told. How much it matters depends on the facts.
• Medical information and consent. Health conditions, emergency contacts, consent to treatment, pickup authorization and photo consent, collected before the activity. For families, the parent's form records consent to the child's participation.

Missouri Activity Laws

• Equine and livestock activities (RSMo 537.325): sponsors must post a statutory WARNING sign (black letters on white, at least one inch tall) near stables, corrals or arenas, and written contracts for services, instruction or rentals must include the warning in clearly readable print. The statute does not protect a sponsor who fails to use ordinary care, so a release still matters for those claims.
• Registered agritourism (RSMo 537.856): registered operators must post a specific warning sign and include the warning in every written contract for a registered agritourism activity.

Points to Raise With Your Attorney

WaiverFile doesn't draft waivers, and the wording of your agreement is a job for you and your attorney. Based on the cases and statutes above, these are points worth raising when preparing a Missouri agreement:

• The word "negligence." Alack is a bright-line rule: courts look for "negligence" or "fault" (or clear equivalents) in the release itself.
• Conspicuousness. The court in Alack faulted a clause buried on the back of a form in the same type as everything else.
• Reasonable understanding. Whether a reasonable person would understand what future claims they were giving up.
• Arbitration and delegation clauses. Karlin turned on the delegation clause.
• Which visits a release covers, and who may sign for a child. Both were disputed in Karlin.
• Statutory warnings. Equine and agritourism operators need the exact warning text.

How WaiverFile Helps Missouri Businesses

Once your agreement is written, WaiverFile makes it easy for every guest to sign it and keeps a complete, easy-to-find record of each one:

• Your agreement, laid out your way. Add the agreement text you and your attorney prepared, and use the editor's formatting options (bold, capitals, font size) to lay it out the way it was written. The wording and format are up to you.
• A checkbox or initials where you want them. Add initial boxes inside the agreement text and required checkboxes for the rules, risks and clauses you choose, so each one has its own acknowledgment.
• Know who signed for each child. A parent or guardian signs for themselves and adds each child by name and date of birth, and minors are flagged at check-in. Add a photo of the signer or their ID with the tablet camera.
• A record for every visit. Each signed form stores the signature, the answers, and the date and time, plus the IP address and device for online signing. With waivers built into online booking, guests sign as part of each booking and you see each guest's status at check-in.
• Medical questions. Required questions capture health conditions and emergency contacts before guests arrive. HIPAA features add extra protection for health information.
• Sign anywhere. Guests sign ahead by email, text, QR code or your website, or on a tablet at the door, and the Venue app works offline.
• Records you can produce. Search any waiver in seconds, or download them in bulk as a ZIP file for any date range.

Start with one of our free waiver templates, adapt it for Missouri with your attorney, and set up a free account to start collecting signatures.

Sources and Further Reading

• RSMo 432.230 (UETA, legal recognition of electronic signatures)
• 15 U.S.C. 7001 (federal ESIGN Act)
• Alack v. Vic Tanny International of Missouri, Inc., 923 S.W.2d 330 (Mo. banc 1996)
• DeCormier v. Harley-Davidson Motor Co. Group, Inc., 446 S.W.3d 668 (Mo. banc 2014)
• Karlin v. UATP Springfield, LLC, No. SC100512 (Mo. banc Mar. 4, 2025)
• RSMo 537.325 (equine and livestock activities)
• RSMo 537.856 (agritourism signs and contract warning)
• Cusumano, "Enforceability of Exculpatory Clauses in Missouri" (UMKC School of Law, 2023)

Published November 4, 2026