Mattie L. Smith v. Six Flags Over Georgia II, Lp

CourtCourt of Appeals of Georgia
DecidedMarch 1, 2024
DocketA23A1431
StatusPublished

This text of Mattie L. Smith v. Six Flags Over Georgia II, Lp (Mattie L. Smith v. Six Flags Over Georgia II, Lp) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mattie L. Smith v. Six Flags Over Georgia II, Lp, (Ga. Ct. App. 2024).

Opinion

SECOND DIVISION MERCIER, C. J., MILLER, P. J., and HODGES, J.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

March 1, 2024

In the Court of Appeals of Georgia A23A1431. SMITH v. SIX FLAGS OVER GEORGIA II, LP.

MILLER, Presiding Judge.

Mattie Smith, the plaintiff in this personal injury action, appeals from the grant

of summary judgment to the defendant Six Flags Over Georgia II, LP (“Six Flags”).

For the reasons that follow, we affirm.

Summary judgment is proper when there is no genuine issue of material fact and the movant is entitled to judgment as a matter of law. OCGA § 9-11-56 (c). A defendant may do this by showing the court that the documents, affidavits, depositions and other evidence in the record reveal that there is no evidence sufficient to create a jury issue on at least one essential element of plaintiff’s case. On appeal, we review the grant or denial of summary judgment de novo, construing the evidence and all inferences in a light most favorable to the nonmoving party. (Citations and punctuation omitted.) Washington v. J.D. Royer Wholesale Florist, 275

Ga. App. 407 (620 SE2d 626) (2005).

So viewed, the evidence here shows that Six Flags operates an amusement park

in Austell, Georgia, which contains a ride called “Up Up and Away.” The ride

consists of suspended baskets that resemble hot air balloons and rise and move in a

circle when the ride is in motion. When the ride is not in motion, the baskets hang

approximately seven inches from the ground. There is a natural and minimal swaying

of the baskets as guests exit them, but the baskets do not move upwards unless the ride

is in operation.

On July 21, 2018, Smith, who had been a season pass holder at the park for

multiple years and had previously ridden the ride on multiple occasions, entered the

ride. When the ride stopped and a Six Flags employee opened the door to Smith’s

basket, she stood up, began to exit the basket, and fell to the ground, injuring herself.

Shortly thereafter, Smith told Six Flags employees that the basket swayed as she

exited.

Smith filed this negligence lawsuit against Six Flags in June 2020, alleging,

among other things, that Six Flags employees (1) failed to warn her that the basket

2 might move while she exited it and (2) prematurely restarted the ride while she was

exiting.

At her deposition on April 9, 2021, Smith only recalled one Six Flags employee

being present at the ride from the time she entered it until the time she fell, explaining

that when the ride finished the employee moved away from the area where she had

operated the ride and let Smith out of her basket before letting other guests out. Smith

testified that this employee called for other employees to help once she fell. Smith

explained that she fell because her basket moved “from left to right.” When asked to

describe the movement of the basket, Smith said, “The only thing I know, it moved

from left to right that’s all I know.” Smith’s acquaintance, who had been on the ride

with her, testified via deposition that one Six Flags employee was operating the ride

and that Smith fell because the basket swayed. Smith did not testify at her deposition

that (1) a Six Flags employee prematurely started the ride while she was exiting the

basket, (2) her basket rose around the time of her fall, or (3) she heard any sounds

while exiting the basket. After Smith’s deposition, Six Flags produced videos of the

ride’s start-up process, which show that the ride emits a buzzing noise as it begins

operating and the baskets move upward.

3 Six Flags filed a motion for summary judgment, arguing that (1) Smith failed to

establish that (a) Six Flags had exposed her to an unreasonable risk of harm, or (b) Six

Flags had superior knowledge of any such risk; and (2) Smith was barred from

recovering for her injuries under the doctrines of prior traversal and assumption of the

risk. Six Flags emphasized that Smith had ridden the ride multiple times before her

fall and asserted that the seven-inch step from the basket to the ground and the natural

swaying of the basket as riders exited constituted open, obvious, and safe conditions.

Smith was given until December 5, 2022, to respond to the motion for summary

judgment. On that day, Smith filed both a response and her own affidavit. Smith

pertinently testified in her affidavit that (1) two Six Flags employees were present

when the ride stopped, one of whom was standing at the ride operating station, and

one of whom was letting riders out of the baskets; (2) as Smith was exiting the basket,

she heard the same buzzing noise that is present in the videos of the ride, and when

the buzzing commenced the basket began moving more than it had been; (3) within

seconds of falling, Smith looked at the basket and noticed that it was at least a foot

higher than it had been when the attendant let her out of the basket; and (4) Smith fell

4 due to the upward movement of the basket. Smith did not attempt to explain in her

affidavit why any testimony therein differed from her deposition testimony.

In responding to Six Flags’ motion for summary judgment, Smith relied on her

affidavit and asserted that Six Flags’ arguments were misplaced because the actions

of its employee in raising the basket as she exited constituted active negligence, and

therefore concepts regarding premises liability and superior knowledge of a hazard

were irrelevant.

Faced with Smith’s affidavit and response to its summary-judgment motion, Six

Flags argued that because the affidavit contradicted Smith’s deposition testimony and

she had offered no reasonable explanation for the contradictions, the contradictory

testimony could not be considered in order to defeat summary judgment. Specifically,

Six Flags argued that in her affidavit Smith provided testimony that contradicted her

deposition by stating that (1) two Six Flags employees were present when she fell, (2)

immediately after falling, she noticed that the basket was at least a foot higher than it

should have been, and (3) she heard a buzzing noise as she exited the basket, and when

she heard the buzzing the basket began to move more significantly. Six Flags argued

5 that in the absence of the contradictory affidavit testimony, there was no evidence that

the basket rose as Smith was exiting it.

Smith’s counsel responded that her affidavit testimony did not contradict her

deposition testimony, and she had a reasonable explanation for any contradictions

because she had no reason to believe the buzzing noise was significant or to associate

it with the movement of her basket until Six Flags produced a video of the ride’s start-

up process.

Following a hearing, the trial court issued an order granting Six Flags summary

judgment. As an initial matter, the court stated that its “primary inquiry” was

“whether Six Flags, as the premises owner/occupier, had superior knowledge of an

unreasonably dangerous condition and failed to warn Smith of it.” Significantly, the

court found that “[t]he testimony in [Smith’s] affidavit is contradictory to her

deposition testimony and alters her previous testimony,” and stated that “any

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Mattie L. Smith v. Six Flags Over Georgia II, Lp, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mattie-l-smith-v-six-flags-over-georgia-ii-lp-gactapp-2024.