Psenicska v. Twentieth Century Fox Film Corp.

Several individuals (plaintiffs), including driving instructor Psenicska and etiquette trainer Martin, were recruited by Fox, Schulman, and actor Sacha Baron Cohen (defendants) to participate in what they believed was a documentary, and were filmed reacting to Cohen's deliberately offensive in-character behavior; before filming, each signed a standard consent agreement waiving all claims related to their participation, including fraud claims based on deception or surprise, and expressly stating they were not relying on any representations about the film's true nature. After the film Borat was released, the participants sued for damages related to their appearances, and the defendants moved to dismiss based on the consent agreements.