Does the doctrine of absolute immunity from liability apply to contracts where the contract contains clauses that completely exempt a party from liability?

Defendants argue that this doctrine applies only to clauses that completely exempt a party from liability, not to those that limit liability. We are not persuaded. Defendants do not cite a single case that supports their argument. Moreover, the rationale behind the doctrine--to prevent parties from shielding themselves from liability for their own fraud by inserting a clause into the very contract that was procured by the fraud--applies equally to the limitation of liability and to the exclusion of liability. See, e.g., Bates v. Southgate, 308 Mass. 170, 171, 31 N.E.2d 551, 555 (1941) ("Attempts under the form of contract to secure total or partial immunity from liability for fraud are all under the ban of the law.") (citation omitted).