Gibson v. Donahue

772 N.E.2d 646, 148 Ohio App. 3d 139
CourtOhio Court of Appeals
DecidedJanuary 18, 2002
DocketAppeal No. C-010265, Trial No. A-0002444.
StatusPublished
Cited by5 cases

This text of 772 N.E.2d 646 (Gibson v. Donahue) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gibson v. Donahue, 772 N.E.2d 646, 148 Ohio App. 3d 139 (Ohio Ct. App. 2002).

Opinions

Mark Philip Painter, Presiding Judge.

{¶ 1} There are no zebras in this case; but there could be. The trial court based its ruling on Ohio’s equine liability immunity law, which defines an “equine” as “a horse, pony, mule, donkey, hinny, zebra, zebra hybrid, or alpaca.” 1 (A similar Florida statute 2 defines an equine as “a horse, pony, mule, or donkey,” leaving one to speculate whether hinny, zebra, zebra hybrid, and alpaca riding are more common — or more deserving of protection — in Ohio than in Florida.) But in our case, a horse is a horse.

{¶ 2} This is a case of first impression in Ohio, probably because no one before has been audacious enough to try to ride the statute to immunity in a case like this one. The trial court granted summary judgment. We reverse.

*142 Donahue’s Dogs Chase Gibson’s Horse, Causing it to Throw Gibson

{¶ 3} Appellant, Ann Sergeant Gibson, was injured after being thrown by her horse while riding in Clippenger Field, located in the City of the Village of Indian Hill (yes, that is its official name). Appellee Susan Donahue owned two full-grown Irish Setters that she allowed to run off-leash in the field, even though the field was clearly marked “This area restricted to Equestrian use only.” Donahue’s dogs chased Gibson’s horse, causing the horse to throw Gibson into a tree with sufficient force to break her helmet. She suffered serious injuries.

{¶ 4} The facts are simple enough, but lawyers and legislators can make things seem complicated. Somehow, Donahue’s lawyers found R.C. 2305.321, entitled “Immunity as to equine activity risks,” which is noteworthy mainly for using the word “farrier” ten times. Because the statute is a bit obscure, we have included it here in its entirety, as an appendix.

{¶ 5} We have found only one Ohio case interpreting this gem of legislative drafting, but that case is not helpful to our issues here. 3 We have also searched in vain for any way that this statute has anything to do with this case.

Three Hurdles

{¶ 6} Gibson’s first assignment of error asserts that summary judgment was improper. We review the grant of summary judgment in favor of Donahue de novo, using the same standard that the trial court applied. 4 Under Civ.R. 56(C), summary judgment for Donahue was appropriate if (1) there was no genuine issue of material fact, (2) Donahue was entitled to judgment as a matter of law, and (3) after construing the evidence most favorably for Gibson, reasonable minds could only reach a conclusion adverse to Gibson. 5

{¶ 7} For Donahue to prevail, she had to clear three legal hurdles by establishing that (1) Indian Hill was the “sponsor” of an “equine event,” (2) Gibson was engaging in an “equine activity” as defined by the statute, and (3) the immunity granted to the sponsor also shielded anyone else. And, as Judge Hildebrandt notes in his concurrence, even if all those hurdles were jumped, another section of the law might trump the equine act.

*143 {¶ 8} The first hurdle is questionable at best, the second even more so, but the third is insurmountable in this case. And, as far as we know, Donahue does not even have a horse, only two dogs.

Did Indian Hill Sponsor Gibson’s Ride?

{¶ 9} The trial court, in granting summary judgment, held that Indian Hill was immune as a “sponsor” of an equine activity. That may or may not be so, but Indian Hill was not even sued. Donahue was sued.

{¶ 10} While it is true that riders must pay a fee to Indian Hill to ride over any property in the city, we are skeptical that this fact alone would make Indian Hill a “sponsor” of any person riding within the city. The city manager of Indian Hill testified as follows:

{¶ 11} “Q: Okay. Is it fair to say that you don’t sponsor any type of equestrian events in Clippenger Field?

{¶ 12} “MR. SKINNER: Objection.

{¶ 13} “MR. PHILLIPS: Objection. Calls for legal conclusion. You can answer.

{¶ 14} “A: You know, I’ve read that section of the law, it’s — to me it’s tough to read so—

{¶ 15} “BY MR. DRINNON: I’m trying to do the best I can.

{¶ 16} “A: I really — I don’t have a conclusion on that as to how we fit into that section of law in terms of what is sponsored and what is an activity.”

{¶ 17} If the meaning of “sponsor” calls for a legal conclusion, then it should be defined in the statute, which it is not. “Equine activity sponsor” is purportedly defined, but it is not a true, but a circular definition — one that uses the word itself to define itself. “Sponsor” is not defined at all. Lacking a statutory definition, we resort to dictionaries. Black’s Law Dictionary states that a sponsor is “1. One who acts as a surety for another. 2. A legislator who proposes a bill. 3. Civil law. One who voluntarily intervenes for another without being requested to do so.” 6 The only definition of sponsor in Webster’s Third International Dictionary, Unabridged, that could be relevant here is “one who assumes responsibility for some other person or thing.” 7

*144 {¶ 18} Neither definition seems to help' Indian Hill, much less Donahue. “Sponsor” as a verb is defined as “to be or stand sponsor for: accept responsibility for.” 8 Of course, the statute seeks to avoid responsibility, not to accept it.

{¶ 19} Perhaps we can glean from the definitions and the statute that the latter seeks to immunize a person or entity that would otherwise be regarded as taking responsibility for an equine activity. Thus interpreted, it makes some sense — why write a statute to immunize activity that would give rise to no liability in the first place? If Indian Hill had indeed sponsored an event, and Gibson’s horse had fallen because of a gopher hole in the field, she might have made a case against the sponsor of the event. In that instance, the statute arguably would have immunized Indian Hill, the sponsor, from that type of “inherent risk of equine activity.” The legislature obviously intended to grant just such immunity. (When the statute is digested, it seems only to immunize activity that would not have given rise to liability under the common law in the first place.) Even had Indian Hill sponsored an event, if Donahue had loosed her dogs to chase the horses in a sponsored event, the immunity would not have shielded her — only the sponsor.

{¶ 20} But even were we to hold that the first hurdle — sponsorship—could be jumped, there are still two more, each progressively higher.

Was Gibson Engaged in an “Equine Activity”?

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Cite This Page — Counsel Stack

Bluebook (online)
772 N.E.2d 646, 148 Ohio App. 3d 139, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gibson-v-donahue-ohioctapp-2002.