Jackson v. Live Nation Entertainment Inc

CourtDistrict Court, E.D. Washington
DecidedAugust 22, 2022
Docket2:20-cv-00233
StatusUnknown

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

Bluebook
Jackson v. Live Nation Entertainment Inc, (E.D. Wash. 2022).

Opinion

1 U.S. FDILISETDR IINC TT HCEO URT EASTERN DISTRICT OF WASHINGTON

Aug 22, 2022 2 SEAN F. MCAVOY, CLERK 3 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 4 JARED JACKSON, No. 2:20-cv-00233-SMJ 5 Plaintiff, 6 ORDER DENYING MOTION FOR v. SUMMARY JUDGMENT 7 LIVE NATION WORLDWIDE INC, a 8 Delaware Corporation; CONSCIOUS ENTERTAINMENT GROUP LLC, a 9 Washington Limited Liability Company; 10 Defendants. 11 Before the Court is Defendants’ Motion for Summary Judgment, ECF No 43. 12 After hearing oral argument on the motion and reviewing the file, the Court is fully 13 informed and finds that Defendants have not met their burden of demonstrating that 14 there are no genuine disputes of material fact. As such, the Court denies the motion 15 for summary judgment. 16 BACKGROUND 17 Defendant Live Nation, via a long-term lease, owns and operates the music 18 performance facility known as “The Gorge” in George, Washington. ECF No. 56- 19 14 at 3. Live Nation contracted with Defendant Conscious Entertainment Group 20 (“CEG”) to put on the 2017 Paradiso Festival, an electronic dance music festival. 1 ECF No. 56-15. The festival had multiple stages on which to perform. ECF No. 56- 2 11 at 4. The stage at issue here, which was not the main stage, was known as the

3 “Wreckage” stage, as it was built to resemble the crash-landing site of a small plane 4 in a tropical jungle. Id.; ECF No. 56-5 at 1. 5 Defendant CEG was the lead event producer for the 2017 Paradiso Festival

6 and was tasked with, among other things, hiring talent and managing production 7 design. ECF No. 56-15 at 2. The stage was designed by Chad Craig, dba A Way of 8 Life Productions, dba AWOL Productions, with CEG having final design approval 9 before sending the designs to its engineering firm, Clark Reder. Id. at 3; ECF No.

10 56-9 at 6. For its part, Live Nation hired engineer Karl Sutter of Kimley-Horn to 11 evaluate the stages before the event began. ECF No. 56-14 at 6. 12 Although the initial stage design was designed for stationary musical

13 performances, a different design was ultimately approved with additional staging to 14 be built off the front of the stage—a feature known as an “ego thrust.” Id. at 9. 15 Defendants argue that the extra feature was added at the request of Plaintiff’s 16 musical group, Keys N Krates, but Plaintiff disputes this.1 See ECF No. 57 at 2.

17 Regardless, this request created a gap in the stage, to the side of the ego thrust. Id. 18 According to the stage’s designer, CEG later asked the for a flat stage design, 19 1 Plaintiff is the sound engineer and tour manager for the group. He was also often 20 the production manager, but not for the 2017 Paradiso Festival. See ECF No. 57 at 3. 1 because Keys N Krates was going to give a “live” performance, as opposed to, the 2 more typical stationary DJ performance. Id. at 10. The stage designer ultimately

3 produced the requested flat stage design, which did not have the “gap” into which 4 Plaintiff eventually fell, ECF No. 56-4 at 4, but the final plans stamped by 5 engineering firm Clark Reder and built at the 2017 Paradiso Festival used the older

6 design, which had the gap, id. at 7. 7 Plaintiff Jackson stood on the stage the day before his injury and on the day 8 of his injury, as late as 2:30 in the afternoon. At the time, he “was aware of many, 9 many gaps and/or missing sections of 4-by-8 or 8-by-8 stage on the stage that day

10 leading up to [the performance].” ECF No. 38 at 29. He “believe[s]” that the gap he 11 ultimately fell in was there at 2:30 in the afternoon. He also acknowledges that 12 “every time you get on a stage there is a risk.” ECF No. 38 at 24. He has seen a

13 dozen incidents that he can “vividly remember or my memory could be jogged for” 14 of people falling off a stage. Id. at 24–25. “From the moment we arrive I knew that 15 there were areas that were either askew, elevated, missing, yes.” id. at 26. He knew 16 that these areas “absolutely could” pose a potential danger and was worried about

17 them. Id. 18 In Jackson’s declaration, attached to his response, he clarifies: 19 Since I had complained to multiple people during the sound check seven hours earlier about the missing stage deck pieces, and that those 20 were safety concerns that needed to be fixed, and the fact that I had been told that more stage decking was coming, I assumed that the gaps 1 had been filled with stage decking prior to falling into the hole. I was worried and concerned about the various gaps on the stage that I saw 2 during the sound check, but assumed that they had been fixed prior to Keys N Krates performance starting. 3 ECF No. 57 at 2. 4 Plaintiff Jackson, who worked hundreds of shows with Keys N Krates, 5 stationed himself, crouched down with his iPad, far stage right to serve as sound 6 engineer for Keys N Krates’ 10:00 P.M. show. See ECF No. 57 at 2. At some point, 7 while holding the iPad in his left hand, he took a video with this phone. Around 8 10:30 P.M., the band’s drummer signals to Plaintiff that something is wrong. 9 Plaintiff then locked the tablet and runs—not sprinting, but “crouched a bit lower 10 and running towards the drummer,” “looking him in the eye.” ECF No. 38 at 28. As 11 he’s running, he falls into the gap, suffering injury. He sued in negligence, seeking 12 monetary damages. Now, Defendants Live Nation and CEG move for summary 13 judgment on three grounds. See ECF No. 43 at 2–3. Defendants Live Nation and 14 CEG, in their reply, also moved for an adverse inference due to spoliation and to 15 strike Plaintiff Jackson’s declaration. ECF No. 86. 16 LEGAL STANDARD 17 A. Summary Judgment 18 Courts must “grant summary judgment if the movant shows that there is no 19 genuine dispute as to any material fact and the movant is entitled to judgment as a 20 matter of law.” Fed. R. Civ. P. 56(a). A fact is “material” if it could affect the suit’s 1 outcome under the governing law. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 2 248 (1986). An issue is “genuine” if a reasonable jury could find for the nonmoving

3 party based on the undisputed evidence. Id. The moving party bears the “burden of 4 establishing the nonexistence of a ‘genuine issue.’” Celotex Corp. v. Catrett, 477 5 U.S. 317, 330 (1986). “This burden has two distinct components: an initial burden

6 of production, which shifts to the nonmoving party if satisfied by the moving party; 7 and an ultimate burden of persuasion, which always remains on the moving party.” 8 Id. 9 B. Washington Negligence and Premises Liability

10 To establish negligence, a plaintiff must prove four basic elements: (1) the 11 existence of a duty, (2) breach of that duty, (3) resulting injury, and (4) proximate 12 cause. Musci v. Graoch Associates Ltd. P’ship No. 12, 31 P.3d 684, 854 (Wash.

13 2001). Whether a duty exists is a question of law. Hutchins v. 1001 Fourth Ave. 14 Assocs., 802 P.2d 1360, 1362 (Wash. 1991). 15 In premises liability actions, a person’s status, based on the common law 16 classifications of persons entering upon real property—invitee, licensee, or

17 trespasser—determines the scope of the duty of care owed by the possessor of that 18 property. Van Dinter v. Kennewick, 846 P.2d 522, 524 (Wash. 1993); see generally 19 W. Keeton, D. Dobbs, R. Keeton & D. Owen, Prosser & Keeton on Torts §§ 58–61

20 (5th ed. 1984) (hereafter Prosser & Keeton on Torts).

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Jackson v. Live Nation Entertainment Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jackson-v-live-nation-entertainment-inc-waed-2022.