Sylvia Rieff v. Jesse James Riding Stables, Inc.

CourtCourt of Appeals of Kentucky
DecidedDecember 1, 2022
Docket2022 CA 000161
StatusUnknown

This text of Sylvia Rieff v. Jesse James Riding Stables, Inc. (Sylvia Rieff v. Jesse James Riding Stables, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sylvia Rieff v. Jesse James Riding Stables, Inc., (Ky. Ct. App. 2022).

Opinion

RENDERED: DECEMBER 2, 2022; 10:00 A.M. TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2022-CA-0161-MR

SYLVIA RIEFF APPELLANT

APPEAL FROM BARREN CIRCUIT COURT v. HONORABLE JOHN T. ALEXANDER, JUDGE ACTION NO. 20-CI-00185

JESSE JAMES RIDING STABLES, INC. APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: CETRULO, COMBS, AND GOODWINE, JUDGES.

CETRULO, JUDGE: Appellant Sylvia Rieff (“Ms. Rieff”) appeals the order of the

Barren Circuit Court granting the motion for summary judgment of the Appellee

Jesse James Riding Stables, Inc. (“JJ Stables”). I. FACTUAL AND PROCEDURAL HISTORY

In April 2019, Ms. Rieff and her two children visited JJ Stables and

took a guided horseback riding tour. Before beginning the tour, Ms. Rieff signed

the “Horse Rental Agreement and Liability Release Form” (the “Release”), which

detailed potential risks of participating in the tour and provided guidance on how to

avoid some injuries, e.g., it recommended wearing a helmet and notifying

employees of concerns with the saddle. Further, the Release outlined the

participant’s assumption of risk and included a liability release for bodily injury

and medical expenses, among other things.

The preamble of the Release stated that the agreement was “by and

between Sylvia Rieff [who had written her name in the blank space provided] who

will sign below for and on behalf of all under-age family members, and those for

whom I am guardian, hereinafter referred to as ‘I/WE,’ and [JJ Stables] . . . .” Ms.

Rieff then wrote each participant’s name, which included herself and her two

children, in Section I of the Release, titled “Registration of Riders.” That section

further stated that “I/WE” included the individuals Ms. Rieff had listed.

Section II, titled “Warnings and Assumption of Risk Agreement,”

stated, in pertinent part, that

I/WE understand . . . that there are inherent elements of risk always present in any such activity despite all safety precautions. I fully accept such risk, some examples of which are listed as follows: . . . Saddle girths may

-2- naturally loosen during a ride and if a rider notices this he should alert the nearest guide as quickly as possible to avoid any slippage of saddle.

Section III, titled “Release Agreement,” detailed the exclusionary

provision of the Release and stated, in pertinent part, that

I/WE understand and agree that except in event of THIS STABLES’S gross negligence, I/WE accept full responsibility for bodily injury, property damage, death, medical and other financial loss expenses to include, but not limited to, time lost from school or work or disability, which are sustained by any member of my group so listed above, on or in relationship to the premises and operations of THIS STABLE and/or while riding or handling horses or other animals owned by same; and that I/WE hereby, for myself, my heirs, administrators and assigns, do hereby release and discharge the owners, operators, sponsors of the premises and their respective servants, agents, officers and all other participants of and from all claims, demands, actions and causes of action for same injuries, damages, and death . . . .

Finally, in Section IV, “Closing Statement and Signatures,” the

Release stated that “THE UNDERSIGNED HAVE READ AND UNDERSTAND

THE FOREGOING AGREEMENT AND RELEASE WAIVER” and provided

three lines for signatures: one of which stated it was solely for a rider; the next

was for signatures of parents, guardians, and/or spouse #1; and a third line was for

signatures of the other parent, guardian, and/or spouse #2. The third line noted that

spouses must sign for themselves. Ms. Rieff signed the second line and circled

“Parent.”

-3- After completing the paperwork, employees of JJ Stables fit Ms. Rieff

and her children for gear and began the tour. Approximately 20 minutes into the

tour, as the trail entered the surrounding woods, Ms. Rieff’s saddle became loose,

and she slid off the side of the horse, falling to the ground. Following the fall, Ms.

Rieff testified that her husband took her to a nearby hospital for x-rays and at some

point in the days that followed, a doctor determined she had broken four ribs and

fractured some vertebrae.

The next year, in March 2020, Ms. Rieff filed a complaint claiming JJ

Stables negligently (1) failed to properly secure the saddle, (2) failed to recognize

the faulty saddling of the horse, (3) provided unsafe equipment, and (4) failed to

properly warn Ms. Rieff of the risk of a loosening saddle. The case proceeded

through discovery, and both parties conducted depositions.

In September 2021, JJ Stables moved for summary judgment,

claiming, in pertinent part,1 that Ms. Rieff’s claims were barred because she signed

the Release, which served as an exculpatory, pre-injury liability waiver. In the

circuit court’s January 2022 order, it granted the motion for summary judgment of

JJ Stables and concluded that “[a]fter a careful review of the [R]elease . . . and

1 JJ Stables also made claims that Kentucky’s Farm Animal Activity Act barred Ms. Rieff’s action; however, the circuit court did not adjudicate that issue – relying instead on its Hargis analysis – and it was not raised on appeal. Hargis v. Baize, 168 S.W.3d 36 (Ky. 2005).

-4- strictly construing it in a light most favorable to [Ms. Rieff], the Court finds that

the [R]elease meets . . . the Hargis tests”2 and therefore was enforceable to waive

JJ Stables’ liability for negligence. Further, the circuit court found that Ms. Rieff

was bound by the Release, individually, because the “first line of the release

indicates that she is a party, and she testified by deposition that she signed the

document. . . . Her signature, combined with her participation on the ride, suffice

to establish that she was a party to the release and is bound by it.”

Ms. Rieff appealed. She now argues that the circuit court erred when

it found (1) the Release was enforceable under Hargis; and (2) that she, individually,

was bound by the Release.

II. STANDARD OF REVIEW

“The standard of review on appeal of a summary judgment is whether

the trial court correctly found that there were no genuine issues as to any material

fact and that the moving party was entitled to judgment as a matter of law.” Scifres

v. Kraft, 916 S.W.2d 779, 781 (Ky. App. 1996) (citing CR3 56.03). Therefore, we

“need not defer to the trial court’s decision on summary judgment and will review

the issue de novo because only legal questions and no factual findings are

2 We discuss the Hargis alternatives, detailed in Hargis v. Baize, 168 S.W.3d 36 (Ky. 2005), in more detail below. 3 Kentucky Rule of Civil Procedure.

-5- involved.” CLK Multifamily Mgmt., LLC v. Greenscapes Lawn & Landscaping,

Inc., 563 S.W.3d 706, 711 (Ky. App. 2018) (citation omitted).

We will review the record “in a light most favorable to the party

opposing the motion for summary judgment and all doubts are to be resolved in his

favor.” Steelvest, Inc. v. Scansteel Serv. Ctr., Inc.,

Related

Lewis v. B & R CORPORATION
56 S.W.3d 432 (Court of Appeals of Kentucky, 2001)
Steelvest, Inc. v. Scansteel Service Center, Inc.
807 S.W.2d 476 (Kentucky Supreme Court, 1991)
O'BRYAN v. Cave
202 S.W.3d 585 (Kentucky Supreme Court, 2006)
Cantrell Supply, Inc. v. Liberty Mutual Insurance Co.
94 S.W.3d 381 (Court of Appeals of Kentucky, 2002)
Hargis v. Baize
168 S.W.3d 36 (Kentucky Supreme Court, 2005)
Wymer v. JH Properties, Inc.
50 S.W.3d 195 (Kentucky Supreme Court, 2001)
First Commonwealth Bank of Prestonsburg v. West
55 S.W.3d 829 (Court of Appeals of Kentucky, 2000)
Scifres v. Kraft
916 S.W.2d 779 (Court of Appeals of Kentucky, 1996)
CLK Multifamily Mgmt., LLC v. Greenscapes Lawn & Landscaping, Inc.
563 S.W.3d 706 (Court of Appeals of Kentucky, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
Sylvia Rieff v. Jesse James Riding Stables, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/sylvia-rieff-v-jesse-james-riding-stables-inc-kyctapp-2022.