Litterer v. Vail

CourtColorado Court of Appeals
DecidedJanuary 30, 2025
Docket24CA0480
StatusUnpublished

This text of Litterer v. Vail (Litterer v. Vail) 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.

Bluebook
Litterer v. Vail, (Colo. Ct. App. 2025).

Opinion

24CA0480 Litterer v Vail 01-30-2025

COLORADO COURT OF APPEALS

Court of Appeals No. 24CA0480 Summit County District Court No. 22CV30043 Honorable Reed W. Owens, Judge

John Litterer,

Plaintiff-Appellant,

v.

Vail Summit Resorts, Inc., a corporation, and Dwight McClure,

Defendants-Appellees.

JUDGMENT AFFIRMED

Division VII Opinion by JUDGE MOULTRIE Lipinsky and Johnson, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced January 30, 2025

Bloch & Chapleau, LLC, Joseph D. Bloch, Trenton J. Ongert, Denver, Colorado, for Plaintiff-Appellant

Bryan Cave Leighton Paisner LLP, Michael J. Hofmann, Kaitlin M. DeWulf, Denver, Colorado, for Defendants-Appellees ¶1 Plaintiff, John Litterer, appeals the district court’s judgment in

favor of defendants, Vail Summit Resorts, Inc. (VSRI), and Dwight

McClure (jointly, the Defendants). We affirm.

I. Background

¶2 In December 2020, Litterer was injured in a snowboarder-

snowmobile collision (the collision) at Breckenridge Ski Resort

(Breckenridge). Litterer snowboarded down the Wirepatch trail and

turned left onto Peak 8 Road, a catwalk1 approved for snowmobile

traffic. Dwight McClure, a VSRI employee, was operating a

snowmobile owned by VSRI on Peak 8 Road. He and Litterer

collided at the intersection of the Wirepatch trail and Peak 8 Road.

¶3 An incident summary that VSRI prepared reported that, in the

moments before the collision, McClure “saw movement above him in

the trees,” attempted to move the snowmobile to the edge of the

road to avoid a collision, and began to bring the snowmobile to a

stop. At the time, McClure was driving the snowmobile at eighteen

1 A “catwalk” is a trail, often used by maintenance or equipment

vehicles, that winds down the entirety of a mountain or joins one slope to another. Anderson v. Vail Corp., 251 P.3d 1125, 1126 n.2 (Colo. App. 2010).

1 miles per hour — seven miles under the catwalk’s twenty-five-mile-

per-hour speed limit.

¶4 According to the incident summary, Litterer made a “high

speed turn onto and across the [catwalk]” before impacting

McClure’s snowmobile. Litterer’s speed “was such that he could not

stop or change direction.” In a later deposition, Litterer said he was

only “one second” away from impact before he saw McClure and

“had no time to make any moves” before the collision.

¶5 In May 2020, Litterer filed a complaint asserting claims

against the Defendants for negligence, negligence per se, extreme

and outrageous conduct, willful and wanton conduct, and reckless

endangerment. Litterer also asserted claims against VSRI for

respondeat superior, negligent entrustment and/or supervision,

negligent hiring, and premises liability.

¶6 The Defendants moved for partial dismissal of Litterer’s

claims, arguing that Colorado’s Premises Liability Act (PLA)

provided the exclusive remedy for Litterer’s common law claims;

Litterer failed to state a claim for extreme and outrageous conduct;

Colorado does not recognize tort claims for willful and wanton

conduct or reckless endangerment; and Litterer failed to allege

2 sufficient facts to support his claims for negligent entrustment

and/or supervision and negligent hiring. The court dismissed

Litterer’s claims against VSRI for negligence, negligence per se,

respondent superior, negligent entrustment and/or supervision,

negligent hiring, and extreme and outrageous conduct because it

concluded that the PLA preempted those claims. The court also

dismissed Litterer’s claims for willful and wanton conduct and

reckless endangerment on the grounds that they are not cognizable

causes of action in Colorado. However, the court declined to

dismiss Litterer’s premises liability claim against VSRI or Litterer’s

claims against McClure for negligence and extreme and outrageous

conduct. And the court allowed Litterer to amend his complaint to

include a claim against McClure alone for negligence per se.

Following this ruling, Litterer sought leave to amend his complaint

to include a claim for exemplary damages against the Defendants,

which the court granted.

¶7 The Defendants then moved for summary judgment, asserting

that Litterer’s claims were barred by three liability waivers Litterer

executed related to his purchase and use of resort season passes —

3 each otherwise known as an “Epic Pass”2 — and that Litterer’s

claims for negligence per se and extreme and outrageous conduct

failed as a matter of law.

¶8 The court determined that the exculpatory agreements related

to Litterer’s Epic Pass for the 2020-21 ski season were valid and

enforceable and, therefore, barred Litterer’s claims for negligence,

negligence per se, and premises liability. The court further

determined that (1) Litterer released all his claims against the

Defendants when he purchased an Epic Pass for the 2022-23 ski

season; (2) VSRI and McClure’s conduct was insufficient as a

matter of law to support a claim for extreme and outrageous

conduct; and (3) Litterer’s claim for exemplary damages could not

stand without an underlying claim for damages.

¶9 On appeal, Litterer asserts the court erred by (1) granting

summary judgment on his negligence per se claim against McClure

because under Miller v. Crested Butte, LLC, 2024 CO 30 — which

2 Vail Resorts Management Company (VRMC) — of which VSRI is a

subsidiary — sells season passes for its resorts through www.EpicPass.com. After a customer purchases a season pass on that website, VRMC sends the customer a physical Epic Pass, “which is required to access Breckenridge Resort (and other resorts) for skiing.”

4 the supreme court decided while this appeal was pending —

negligence per se claims cannot be barred by exculpatory

agreements; (2) finding that he released all his claims against the

Defendants when he purchased the 2022-23 Epic Pass;

(3) dismissing his claim for willful and wanton conduct against the

Defendants; and (4) rejecting his claim for exemplary damages.

¶ 10 Because we conclude that Litterer’s claims are barred by the

liability waiver he signed when he purchased the 2022-23 Epic

Pass, we do not reach his contention that the supreme court’s

decision in Miller announced a blanket rule prohibiting ski resorts

from using exculpatory agreements to bar negligence per se claims

based on any statute, not just the two statutes — the Ski Safety Act

of 1979 and the Passenger Tramway Safety Act — at issue in that

case. But we address — and reject — his remaining contentions in

turn.

II. The 2022 Online Waiver Bars Litterer’s Claims

¶ 11 The Defendants contend that Litterer released any existing

claims against them when he executed the liability waiver included

with his purchase of a 2022-23 Epic Pass. We agree.

5 A. Additional Facts

¶ 12 Litterer agreed to three liability waivers when he purchased

season passes and obtained a season pass card from VSRI in 2020

and 2022. First, Litterer purchased an Epic Pass for the 2020-21

ski season through www.EpicPass.com. When he purchased that

pass, Litterer executed a “Release of Liability, Waiver of Claims,

Assumptions of Risk Warning and Indemnification Agreement” on

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