Quick Summary
John Coomer (plaintiff) attended a Kansas City Royals (defendant) game and was injured when hit by a hotdog thrown by the mascot. Coomer filed suit for negligence.
The dispute centered around whether such an incident is an inherent risk of attending a game. The Supreme Court of Missouri held that it is not and vacated the jury’s verdict in favor of the Royals, remanding for further proceedings.
Facts of the Case
John Coomer (plaintiff), a dedicated baseball fan, was enjoying a Kansas City Royals (defendant) game when a hotdog, thrown by the team’s mascot during a customary entertainment activity, struck him in the eye.
This incident occurred amidst the ‘Hotdog Launch’, a regular entertainment feature at Royals home games where the mascot, Sluggerrr, tosses hotdogs into the stands. Unfortunately, Coomer did not see the hotdog coming as he turned to look at the scoreboard, resulting in his injury.
Coomer’s injury led to significant medical issues, including a detached retina and a cataract, necessitating surgical interventions. Following the incident and the resulting harm, Coomer sought legal recourse against the Kansas City Royals for Sluggerrr’s alleged negligence and the damages incurred.
Procedural History
- The plaintiff, John Coomer, filed a lawsuit against the Kansas City Royals Baseball Corporation, alleging negligence and battery.
- The trial court dismissed the battery claim and proceeded with the negligence claim.
- The jury found in favor of the Royals, concluding that being hit by a hotdog was an inherent risk of attending a Royals game.
- Coomer appealed the decision.
I.R.A.C. Format
Issue
Whether being struck by a hotdog thrown by a baseball team mascot is an inherent risk of attending a baseball game, for which the team cannot be held liable.
Rule of Law
Inherent risks associated with attending a sporting event do not require a duty of care from the event organizer or team to protect spectators from such risks. However, if an injury results from a risk not inherent to the sport or if the organizer’s negligence increases an inherent risk, liability may be imposed.
Reasoning and Analysis
The Missouri Supreme Court identified that determining what constitutes an inherent risk is a question of law, not fact. The Court distinguished between risks directly associated with the sport itself and those that are ancillary entertainment activities.
It concluded that while spectators assume certain risks when watching baseball, such as foul balls entering the stands, these do not extend to risks arising from promotional activities like mascot-led hotdog tosses.
Furthermore, the Court reasoned that unlike foul balls, which are unavoidable during gameplay, tossing hotdogs is not essential to the sport of baseball and can be conducted in a non-negligent manner.
Therefore, Sluggerrr’s method of tossing could be subject to scrutiny for negligence. The inclusion of assumption of risk in the jury instructions was deemed improper as it may have led to an incorrect verdict absolving the Royals of liability despite potential negligence.
Conclusion
The judgment in favor of the Kansas City Royals was vacated and the case was remanded for further proceedings consistent with this opinion.
Key Takeaways
- The concept of inherent risk is crucial in determining liability at sporting events.
- The Missouri Supreme Court holds that not all activities at a baseball game are protected under the doctrine of assumption of risk.
- Judicial determination of what constitutes an inherent risk is essential to ensure consistent legal standards.
Relevant FAQs of this case
What is the legal distinction between inherent risks and added risks in terms of liability at a sporting event?
In legal terms, inherent risks are those which are naturally part of the sport and are thus assumed by participants and spectators. Liability for injuries stemming from inherent risks is typically not imposed on event organizers. Added risks, however, are those that do not naturally occur during the course of a game and are introduced by either negligence or additional activities. Organizers may be held liable if injuries result from such added risks.
- For example: In the case of a fan being injured by a foul ball, which is considered an inherent risk of baseball, the stadium would likely not be liable. However, if a fan is injured due to malfunctioning equipment unrelated to the game itself, like a collapsed seat, this could be an added risk leading to potential liability for the stadium.
How does assumption of risk apply to non-sporting elements during a sports game?
Assumption of risk applies to scenarios foreseeable in the context of the sporting event. For non-sporting elements, such as entertainment acts or promotional activities that happen during a game but are not part of the sport itself, assumption of risk may not protect organizations from liability if an injury ensues due to these events.
- For example: If a spectator at a hockey game is injured during an intermission contest where they slip on ice on the rink surface, it can be argued it’s an unforeseen risk not assumed by the spectator since it’s not part of watching the hockey match.
How might organizational negligence alter the scope of assumed risks for spectators?
Organizational negligence alters the scope of assumed risks by introducing hazards that go beyond what spectators reasonably consent to face. When negligence increases inherent risks or introduces new dangers, it can negate assumed risk defenses and lead to potential liability for organizations.
- For example: If a basketball game attendee is injured because venue staff negligently spilled water on the stairs creating a slip hazard, this act goes outside the ordinary assumed risks of watching basketball, thus potentially imposing liability on the venue.
References
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