Champion v. Feld Entertainment, Inc.

CourtDistrict Court, S.D. California
DecidedMay 6, 2021
Docket3:20-cv-02400
StatusUnknown

This text of Champion v. Feld Entertainment, Inc. (Champion v. Feld Entertainment, Inc.) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Champion v. Feld Entertainment, Inc., (S.D. Cal. 2021).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 SCOTT CHAMPION, et al., Case No.: 20-cv-2400-DMS-KSC

12 Plaintiffs, ORDER GRANTING DEFENDANTS’ 13 v. MOTION TO DISMISS 14 FELD ENTERTAINMENT, INC.. a Delaware Corporation; FELD MOTOR 15 SPORTS, INC., a Delaware Corporation; 16 DIRT WURX USA, LLC, a New York Limited Liability Company; Does 1 17 through 100, 18 Defendants. 19 20 Pending before the Court is Defendants Feld Entertainment, Inc., Feld Motor Sports, 21 Inc., and Dirt Wurx USA, LLC’s (“Defendants”) motion to dismiss Plaintiffs’ Complaint. 22 Plaintiffs filed a response in opposition, and Defendants filed a reply. For the following 23 reasons, the Court grants the motion. 24 I. 25 BACKGROUND 26 This case arises out of Plaintiffs’ participation in a “Supercross” motocross race 27 event run by Defendants, which took place on February 2, 2019, at the Petco Park stadium 28 1 in San Diego, California. (Compl., ECF No. 1, ¶ 1.) 2 Plaintiffs are experienced motocross riders who allege they were injured while 3 participating in the Supercross event as a result of Defendants’ decision to add caustic lime, 4 or quicklime, to the racetrack’s soil. (Id. ¶¶ 5–11, 18.) Caustic lime is a substance used in 5 the construction industry to dry soil so that construction can continue during rain. (Id. 6 ¶ 19.) It can cause burns, irritate skin and eyes, and must be washed off skin upon contact 7 to prevent severe injury. (Id.) If caustic lime is not mixed thoroughly with the soil and 8 properly compacted, it will leach out of the soil. (Id. ¶ 20.) Plaintiffs allege Defendants 9 decided to add caustic lime to the soil because they knew rain was forecast for the date of 10 the Supercross event, and that the rain would cause the outdoor dirt track to become wet 11 and muddy. (Id. ¶ 18.) Plaintiffs claim Defendants did not properly mix the caustic lime 12 into the soil or did not properly compact the soil. (Id. ¶ 22.) Plaintiffs allege Defendants 13 knew or should have known that the rain would cause the lime to leach out of the soil and 14 injure race participants, but that Defendants did not warn participants about this danger or 15 take action to protect participants from this danger. (Id.) 16 Based on these alleged facts, Plaintiffs filed the present action in this Court on 17 December 9, 2020, alleging a claim for gross negligence. (Id.) Plaintiffs seek damages, 18 including punitive damages, and costs. (Id., Prayer for Relief.) Defendants filed a motion 19 to strike and a motion for more definite statement (ECF Nos. 6, 7), and now move to 20 dismiss (ECF No. 10). 21 II. 22 LEGAL STANDARD 23 A motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6) tests the 24 legal sufficiency of the claims asserted in the complaint. Fed. R. Civ. P. 12(b)(6); Navarro 25 v. Block, 250 F.3d 729, 731 (9th Cir. 2001). In deciding a motion to dismiss, all material 26

27 1 Although Plaintiffs’ Complaint alleges this event took place on February 4, 2019, Plaintiffs acknowledge this was an error and that the correct date is February 2, 2019. (Pls.’ 28 1 factual allegations of the complaint are accepted as true, as well as all reasonable inferences 2 to be drawn from them. Cahill v. Liberty Mut. Ins. Co., 80 F.3d 336, 338 (9th Cir. 1996). 3 A court, however, need not accept all conclusory allegations as true. Rather, it must 4 “examine whether conclusory allegations follow from the description of facts as alleged by 5 the plaintiff.” Holden v. Hagopian, 978 F.3d 1115, 1121 (9th Cir. 1992) (citation omitted). 6 A motion to dismiss should be granted if a plaintiff’s complaint fails to contain “enough 7 facts to state a claim to relief that is plausible.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 8 570 (2007). “A claim has facial plausibility when the plaintiff pleads factual content that 9 allows the court to draw the reasonable inference that the defendant is liable for the 10 misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Twombly, 550 11 U.S. at 556). 12 III. 13 DISCUSSION 14 Defendants move to dismiss, raising two main arguments: first, that any claim for 15 ordinary negligence is barred by Plaintiffs’ assumption of risk and signed liability releases, 16 and second, that Plaintiffs fail to plead gross negligence. The Court declines to address 17 Defendants’ ordinary negligence arguments, because even assuming Defendants are 18 correct, these arguments do not foreclose a claim of gross negligence.2 Plaintiffs’ 19

20 2 Gross negligence is not necessarily a separate cause of action from ordinary negligence, 21 but provides a theory under which a defendant may be liable even where a release bars liability for ordinary negligence. See Hass v. RhodyCo Prods., 236 Cal. Rptr. 3d 682, 22 697–98 (Cal. Ct. App. 2018). The Court thus also declines to consider the liability waivers 23 submitted in support of Defendants’ motion to dismiss because these liability waivers are not applicable to a claim of gross negligence. See City of Santa Barbara v. Superior Ct., 24 161 P.3d 1095, 1097 (Cal. 2007) (“[A]n agreement made in the context of sports or 25 recreational programs or services, purporting to release liability for future gross negligence, generally is unenforceable as a matter of public policy.”). Similarly, under the primary 26 assumption of risk doctrine, “the defendant owes no duty to protect a plaintiff from 27 particular harms arising from ordinary, or simple negligence,” Kim v. Cty. of Monterey, 256 Cal. Rptr. 3d 525, 536 (Cal. Ct. App. 2019), but may still be liable for more aggravated 28 1 Complaint is specifically premised on a theory of gross negligence, and the Court 2 accordingly turns to the question of whether Plaintiff has sufficiently stated a claim. 3 “Gross negligence is pleaded by alleging the traditional elements of negligence: 4 duty, breach, causation, and damages.” Rosencrans v. Dover Images, Ltd., 122 Cal. Rptr. 5 3d 22, 31 (Cal. Ct. App. 2011). However, to state a claim for gross negligence, the plaintiff 6 must allege “extreme conduct” by the defendant. Id. The alleged conduct must rise to the 7 level of “either a want of even scant care or an extreme departure from the ordinary 8 standard of conduct.” Id. (quoting City of Santa Barbara v. Superior Ct., 161 P.3d 1095, 9 1099 (Cal. 2007) (internal quotation marks omitted). 10 Plaintiffs allege Defendants’ “use of caustic lime in events such as the Supercross 11 Event . . . was an extreme departure from the standard of care in the industry” and subjected 12 Plaintiffs to a risk of injury outside the risks inherent in motocross events. (Compl. ¶ 21; 13 see id. ¶ 25.) Defendants argue Plaintiffs’ allegations are conclusory, and that Plaintiffs 14 fail to allege facts establishing the ordinary standard of care. The Court agrees. 15 In a sports context, “the relevant duty of care is a duty not to increase the risks to a 16 participant over and above those inherent in the sport.” Kim v. Cty. of Monterey, 256 Cal. 17 Rptr. 3d 525, 537 (Cal. Ct. App. 2019), review denied (Mar. 25, 2020).

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Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
City of Santa Barbara v. Superior Court
161 P.3d 1095 (California Supreme Court, 2007)
Hass v. Rhodyco Prods.
236 Cal. Rptr. 3d 682 (California Court of Appeals, 5th District, 2018)
Lopez v. Smith
203 F.3d 1122 (Ninth Circuit, 2000)
Navarro v. Block
250 F.3d 729 (Ninth Circuit, 2001)
Mayall ex rel. H.C. v. USA Water Polo, Inc.
174 F. Supp. 3d 1220 (C.D. California, 2016)
Holden v. Hagopian
978 F.3d 1115 (Ninth Circuit, 1992)

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Champion v. Feld Entertainment, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/champion-v-feld-entertainment-inc-casd-2021.