Castle v. Jim's Auction

CourtColorado Court of Appeals
DecidedOctober 23, 2025
Docket23CA1680
StatusUnpublished

This text of Castle v. Jim's Auction (Castle v. Jim's Auction) is published on Counsel Stack Legal Research, covering Colorado Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Castle v. Jim's Auction, (Colo. Ct. App. 2025).

Opinion

23CA1680 Castle v Jim’s Auction 10-23-2025

COLORADO COURT OF APPEALS

Court of Appeals No. 23CA1680 Montrose County District Court No. 22CV30037 Honorable Mary E. Deganhart, Judge

Jared Castle, Laura Castle, and Tanner Castle,

Plaintiffs-Appellants,

v.

Jim’s Auction Service, Inc.,

Defendant-Appellee.

JUDGMENT AND ORDER REVERSED, AND CASE REMANDED WITH DIRECTIONS

Division VI Opinion by JUDGE WELLING Brown and Moultrie, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced October 23, 2025

Western Slope Law, Nelson A. Waneka, Glenwood Springs, Colorado; Doehling Law, P.C., Keller A. Caubarreaux, Joseph H. Azbell, Grand Junction, Colorado, for Plaintiffs-Appellants

Wegener Lane & Evans, P.C., Dalen B. Porter, Grand Junction, Colorado, for Defendant-Appellee ¶1 In this Premises Liability Act (PLA) case, plaintiffs, Tanner

Castle, Jared Castle, and Laura Castle1 (collectively, the Castles),

appeal (1) the trial court’s pretrial determination that Tanner was a

“licensee” as a matter of law at the time of his injury; and (2) the

court’s dismissal, after a bench trial, of the Castles’ premises

liability action against the defendant, Jim’s Auction Service, Inc.

(Jim’s Auction). We reverse the judgment and remand the case with

directions.

I. Background

A. Factual Background

¶2 From February 6 to 8, 2021, Jim’s Auction held its annual

machinery consignment auction (the 2021 auction). The 2021

auction was open to the public. Fourteen-year-old Tanner

accompanied his parents, Jared and Laura, to the 2021 auction on

February 6 and 8. All three members of the Castle family helped

out at the 2021 auction in some capacity, and Tanner and his

father also attended the auction to purchase a vehicle for Tanner to

1 Given that all the individual members of the Castle family share a

last name, we will refer to them by their first names (e.g., Jared, Laura, or Tanner). We mean no disrespect by doing so.

1 drive once he turned fifteen and obtained his driving permit.

During the 2021 auction, Tanner was seriously injured while

operating a rope gate and before he could bid on a vehicle.

¶3 Nolan Kearns owns Jim’s Auction. For thirty-five years, Jim’s

Auction had utilized a rope gate to secure an exit on the auction

grounds that led to a nearby county road. The person working the

rope gate had to lower the rope to the ground to allow vehicles to

pass over the rope to exit the auction and enter the adjacent county

road. Once a vehicle had passed over the rope, the person working

the rope gate would raise the rope and attach the loose end of the

rope to a fence to prevent vehicles from passing through the rope

gate until authorized to do so. Until the date of Tanner’s injury,

those who operated the rope gate did so without issue. Every

attendee at the 2021 auction who purchased a vehicle or piece of

equipment had to exit the auction grounds through the rope gate.

¶4 For the 2021 auction, Kearns modified the rope gate, changing

how the rope attached to the fence when in the “closed” position.

Kearns added an additional piece of nylon to the end of the rope

and created a slipknot at the end of the nylon. To open and close

2 the new rope gate, the operator had to place the slipknot over a

piece of rebar attached to the fence.

¶5 During the previous year’s auction (the 2020 auction), Tanner

had performed miscellaneous tasks over the course of the three-day

auction, including working the rope gate without issue. After the

conclusion of the 2020 auction, Jim’s Auction paid Tanner for his

work.

¶6 For the 2021 auction, Jim’s Auction employed Tanner’s

mother, Laura, as an auction clerk, and Kearns asked Tanner’s

father, Jared, to help the day of the auction by starting the vehicles

to be auctioned off. Jim’s Auction paid Laura for her work and

Jared for his help. Tanner helped his father start vehicles for the

auction on both February 6 and 8, in addition to engaging in other

“job duties” around the auction grounds. While Tanner wasn’t an

employee of Jim’s Auction during the 2021 auction season, Tanner

expected Jim’s Auction to pay him for helping, just as it had paid

him for his help during the 2020 auction.

¶7 Jim’s Auction employed Tanner’s seventeen-year-old cousin,

Tyler Reed, to work the 2021 auction. Reed’s primary duty was to

operate the rope gate. Before the 2021 auction, Kearns showed

3 Reed how to operate the new rope gate. Specifically, Kearns

instructed Reed to not hold onto the rope when a vehicle was

present and passing over the rope gate. On the Saturday before the

2021 auction began, Reed showed Tanner how to work the new

rope gate, and Tanner briefly worked the new rope gate that day

without issue.

¶8 On February 8, 2021, after Tanner had finished helping Jared

start vehicles for the 2021 auction and visited the employee food

shack, Tanner went to see Reed, who was working at the new rope

gate. While Tanner was with Reed at the new rope gate, another

employee of Jim’s Auction asked Reed to run an errand at a

different location on the auction grounds. Reed, in turn, asked

Tanner to operate the rope gate while he ran the errand. Tanner

did as Reed requested.

¶9 After Tanner had worked the rope gate for several minutes, a

pickup truck pulling a flatbed trailer approached the rope gate.

Tanner lowered the rope to allow the pickup to pass over it. As the

pickup passed from the auction grounds onto the county road, the

rope became entangled with the pickup truck and the rope wrapped

4 tightly around Tanner’s left index and middle fingers, amputating

them. Tanner’s middle finger was later reattached.

B. Procedural History

¶ 10 The Castles filed suit against Jim’s Auction, asserting a single

claim under the PLA and seeking damages for Tanner’s injury. In

the complaint, the Castles alleged that Tanner was an “invitee”

under the PLA, and that Jim’s Auction breached the duty it owed to

him commensurate with that status.

¶ 11 The case proceeded to discovery, which included depositions of

the Castles and Kearns. The parties agreed that Tanner was an

invitee when he first entered the property the morning of February

8, 2021, because, among other things, he had a business purpose

for attending the auction. The parties disagreed, however, on

whether Tanner was still an invitee at the time he was injured while

operating the rope gate. It was Jim’s Auction’s position that

Tanner’s status changed from invitee to licensee sometime prior to

Tanner’s injury. In accord with this position, Jim’s Auction filed a

C.R.C.P. 56(h) motion, seeking a pretrial determination as a matter

of law that Tanner was a “licensee” under the PLA at the time he

was injured. The Castles contested the motion, arguing that

5 Tanner was an “invitee” at all times, including at the time he was

injured.

¶ 12 In their briefing, the parties concurred that the question of

Tanner’s status at the time of his injury was a question of law that

the court could determine on the record before it. At the parties’

invitation, the court made the determination of Tanner’s status at

the time he was injured without a hearing. After reviewing the

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