THE MAYOR AND ALDERMAN OF GARDEN CITY v. HARRIS

302 Ga. 853
CourtSupreme Court of Georgia
DecidedJanuary 29, 2018
DocketS17G0692
StatusPublished
Cited by4 cases

This text of 302 Ga. 853 (THE MAYOR AND ALDERMAN OF GARDEN CITY v. HARRIS) is published on Counsel Stack Legal Research, covering Supreme Court of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
THE MAYOR AND ALDERMAN OF GARDEN CITY v. HARRIS, 302 Ga. 853 (Ga. 2018).

Opinion

302 Ga. 853 FINAL COPY

S17G0692. THE MAYOR AND ALDERMEN OF THE CITY OF GARDEN CITY v. HARRIS et al.

MELTON, Presiding Justice.

This case concerns the proper statutory interpretation of the Recreational

Property Act, OCGA § 51-3-20 et seq. (RPA), which shields from potential

liability landowners who “either directly or indirectly invite[ ] or permit[ ]

without charge any person to use the[ir] property for recreational purposes.”

OCGA § 51-3-23. We granted certiorari in this case to determine whether the

Court of Appeals erred in concluding that a landowner would not be shielded

from potential liability by the RPA where that landowner charged a fee to some

people who used the landowner’s property for recreational purposes, but did not

charge any fee to the injured party who used the property for such purposes. The

Mayor and Alderman of the City of Garden City v. Harris, 339 Ga. App. 452

(793 SE2d 628) (2016). As explained more fully below, because the plain

language of the RPA shields a landowner from potential liability under the circumstances presented here, the Court of Appeals erred in concluding

otherwise, and we must reverse.

By way of background, on November 10, 2012, Willie and Kristy Harris,

along with their six-year-old daughter, Riley, attended a youth football game at

the Garden City Stadium, a facility owned and maintained by the City of Garden

City. Willie and Kristy each paid the required $2 admission fee for spectators

over the age of six. However, because Riley was only six years old, the Harrises

were not required to pay an entrance fee for her, and Riley was admitted to the

event free of charge. At one point during the game, while Riley was walking

across the bleachers to return to her seat after visiting the concession stand, she

slipped and fell between the bench seats and suffered serious injuries after

falling to the ground nearly thirty feet below.

The Harrises sued the City to recover for Riley’s injuries, and the City

moved for summary judgment, relying on the immunity provided by the RPA.

Specifically, OCGA § 51-3-23 states:

Except as specifically recognized by or provided in Code Section 51-3-25, an owner of land who either directly or indirectly invites or permits without charge any person to use the property for recreational purposes does not thereby: (1) Extend any assurance that the premises are safe for any purpose; (2) Confer upon such

2 person the legal status of an invitee or licensee to whom a duty of care is owed; or (3) Assume responsibility for or incur liability for any injury to person or property caused by an act of omission of such persons.

And, with respect to the exceptions specifically recognized in OCGA § 51-3-25,

that Code section states in relevant part:

Nothing in this article limits in any way any liability which otherwise exists . . . [f]or injury suffered in any case when the owner of land charges the person or persons who enter or go on the land for the recreational use thereof. . . .

OCGA § 51-3-25 (2).

The City argued that, because Riley was not one of the persons who was

charged a fee to use the City’s property for recreational purposes, the City could

not be held liable for Riley’s injuries as a matter of law. However, the trial court

denied the City’s motion for summary judgment, and the Court of Appeals

affirmed the trial court’s ruling on appeal.

In order to determine whether the Court of Appeals erred in upholding the

trial court’s ruling, we must analyze the relevant provisions of the RPA

mentioned above. In interpreting these statutory provisions, we must presume

that the General Assembly meant what it said and said what it meant. To that end, we must afford the statutory text its plain and ordinary meaning, we must view the statutory text in the context in

3 which it appears, and we must read the statutory text in its most natural and reasonable way, as an ordinary speaker of the English language would . . . [and] if the statutory text is clear and unambiguous, we attribute to the statute its plain meaning, and our search for statutory meaning is at an end.

(Citations and punctuation omitted.) Deal v. Coleman, 294 Ga. 170, 172-173 (1)

(a) (751 SE2d 337) (2013).

With these principles in mind, a natural reading of the plain language of

OCGA § 51-3-23 indicates that a landowner remains free from potential liability

to any individual person who is injured on the landowner’s property who has

been allowed to use the property for recreational purposes free of charge.

Indeed, a landowner

who either directly or indirectly invites or permits without charge

any person to use the property for recreational purposes does not

thereby . . . [c]onfer upon such person the legal status of an invitee

or licensee to whom a duty of care is owed; or . . . [a]ssume

responsibility for or incur liability for any injury to person or

property caused by an act of omission of such persons.

(Emphasis supplied.) The statute specifically and unambiguously references

“any person” who is not charged a fee to use a landowner’s property for

4 recreational purposes as being such a “person” to whom the landowner does not

owe a duty of care. Because the statutory text of OCGA § 51-3-23 is clear and

unambiguous, we attribute to the statute its plain meaning of shielding

landowners from potential liability to individual persons whom they have

invited to use their property for recreational purposes free of charge, “and our

search for statutory meaning is at an end.” Deal, supra, 294 Ga. at 173 (1) (a).

Our interpretation of the plain meaning of OCGA § 51-3-23 is not

diminished when the statute is considered in the context of the exceptions to the

statute set forth in OCGA § 51-3-25. Again, pursuant to OCGA § 51-3-25 (2):

“Nothing in this article limits in any way any liability which otherwise exists .

. . [f]or injury suffered in any case when the owner of land charges the person

or persons who enter or go on the land for the recreational use thereof[.]”

(Emphasis supplied.) Read in conjunction with the other provisions of the

statute, it is plain that, in any case where the injured party is a person who has

been charged a fee to use the landowner’s property for recreational purposes, the

landowner would not be immune from potential liability to such paying persons,

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Bluebook (online)
302 Ga. 853, Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-mayor-and-alderman-of-garden-city-v-harris-ga-2018.