Uline Ice, Inc. v. Sullivan

187 F.2d 82, 88 U.S. App. D.C. 104, 1950 U.S. App. LEXIS 2344
CourtCourt of Appeals for the D.C. Circuit
DecidedDecember 21, 1950
Docket10586
StatusPublished
Cited by15 cases

This text of 187 F.2d 82 (Uline Ice, Inc. v. Sullivan) is published on Counsel Stack Legal Research, covering Court of Appeals for the D.C. Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Uline Ice, Inc. v. Sullivan, 187 F.2d 82, 88 U.S. App. D.C. 104, 1950 U.S. App. LEXIS 2344 (D.C. Cir. 1950).

Opinion

WASHINGTON, Circuit Judge.

This appeal raises the question of the liability or non-liability of the proprietor of a sports arena to a patron-spectator injured during the course of an ice hockey game.

Mr. and Mrs. Sullivan were asked to join a party of friends who planned to attend a professional ice hockey game on the evening of March 19, 1946, at the defendant’s arena. One of the party, who had been a frequent spectator at ice hockey games, purchased the tickets, selecting seats in one of the more expensive sections of the arena. Mr. Sullivan reimbursed him for two of the tickets, and the group went to the arena together. The game had already started. They were conducted to their seats, which were in the front row, on the sideline near the end zone, with an unobstructed view of the play near the goal. The seats directly behind the goal line, at the end of the playing area, were screened by a wire mesh. The seats occupied by the Sullivans and their party were the first group of seats in the unscreened open-view area adjacent to the screened section. It was the first time that Mr. and Mrs. Sullivan had seen a game of ice hockey. They are natives of Tennessee, where the sport is seldom played, and had recently moved to Washington.

During the course of the game — apparently about halfway through — the hockey puck came flying up and out of the playing area, and struck Mrs. Sullivan in the face. The lenses of her spectacles were crushed, pieces of glass being driven into her eyes. She was taken to a hospital for treatment. About 98 per cent of the vision of her right eye has been lost. Suit was brought by her and her husband against the defendant company, the husband seeking damages for medical expenses and loss of consortium. The verdict and judgment awarded $17,000 in damages to Mrs. Sullivan, and $3,000 to Mr. Sullivan. The defendant company appeals.

Appellant alleges that it was not negligent, and that in any event Mrs. Sullivan assumed the risk of injury. It assigns as error the denial by the trial court of appellant’s motion for a directed verdict, the granting of certain instructions requested by appellees, the denial of certain instructions requested by appellant, and the charge in its entirety.

First, as to the question whether appellant was negligent. It is not disputed that during a typical game the hockey puck leaves the playing area several times, and that it may fly into the seats in the side area as well as into the screens at the end areas, although the latter is the more usual. There was testimony that, despite this possible danger to those sitting at the sides, in all arenas in the country a portion of the side area is not screened; that approximately 60 per cent of the arenas have the same amount of screening as the Uline Arena, or less; and that the remaining arenas provide a larger screened area than does appellant (protecting seats comparable to those occupied by the Sullivans). Finally, there was testimony that no arena, by signs, or otherwise, warns patrons that by sitting in unscreened areas they are in possible danger of being hit by the puck.

Appellant argues that because it applied what it considered the customary amount of protection, it could not, as a *84 matter of law, be negligent; that it was entitled to a directed verdict, or at least to a charge that if it provided the customary protection, it had exercised due care. The trial court, on the other hand, considered that what was customary and usual was merely .persuasive as to what constituted due care, and that the matter was one for the jury. 1 We think the trial court was correct. First, in view of the testimony that in 40 per cent of the arenas there was a greater screened area, it is questionable that appellant has established that the protection it provided was the customary amount. But apart from that, what is customary may very well be improvident. It is true that the exhibitor of a sports event is not an absolute insurer of the safety of the patron. But the mere fact that exhibitors generally provide a certain measure of protection to spectators does not preclude the possibility that reasonable men would have provided a greater measure. “What usually is done may be evidence of what ought to be done, but what ought to be done is fixed by a standard of reasonable prudence, whether it usually is complied with or not.” 2 “ * * * otherwise those promoting such forms of amusement could create a rule of law for their own exemption.” 3 Appellant argues, however, that additional screening was not feasible, because the spectators do not desire to have their vision blocked by wiring and the requisite supports. Appellant further contends that to post notices warning spectators of the danger of sitting in unscreened areas would be superfluous because the danger is common knowledge, or at least is obvious to anyone who sees the screening, and observes the game for a few moments. But the questions whether a reasonably prudent operator would 'have provided additional screening, despite the usual practice and the desires of the customers, and whether a reasonably prudent operator would have provided notices for the benefit of the unwary or uninformed, 4 *85 were for the jury. 5 We think the instructions adequately presented these questions to the jury, and further, that the evidence supports the jury’s finding that the appellant was negligent.

This brings us to the question of assumption of risk. There have been many decisions involving this question in cases where spectators were injured at sporting events, primarily in attending baseball games. In the baseball cases, with few exceptions, it generally has been held that, as a matter ■of law, the spectator assumes the risk of the normal hazards of watching such a game; and that, as a matter of law, the danger of being hit by a ball which flies into an unscreened area is a normal hazard, within the common knowledge possessed by reasonably prudent persons. 6 There are also several decisions in cases involving an injury, similar to that which occurred here, to spectators of hockey games. These decisions are conflicting. The courts of four states have held that the question of assumption of risk is one of fact for the jury, which must determine whether the game’s dangers are common knowledge attributable to the plaintiff, and, if not, whether the particular spectator had knowledge of the hazards involved.* 7 The courts of three states follow the rule established in the baseball cases. 8 Appellant contends that the latter rule is the one which should be applied here, and that appellee, by selecting unscreened seats, assumed the risk of the injury she incurred.

The trial court determined that the jury must decide the question of assumption of risk. The jury was charged that if Mrs.

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187 F.2d 82, 88 U.S. App. D.C. 104, 1950 U.S. App. LEXIS 2344, Counsel Stack Legal Research, https://law.counselstack.com/opinion/uline-ice-inc-v-sullivan-cadc-1950.