Vilhauer v. Horsemens' Sports, Inc.

1999 SD 93, 598 N.W.2d 525, 1999 S.D. LEXIS 114
CourtSouth Dakota Supreme Court
DecidedJuly 21, 1999
DocketNone
StatusPublished
Cited by17 cases

This text of 1999 SD 93 (Vilhauer v. Horsemens' Sports, Inc.) is published on Counsel Stack Legal Research, covering South Dakota Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Vilhauer v. Horsemens' Sports, Inc., 1999 SD 93, 598 N.W.2d 525, 1999 S.D. LEXIS 114 (S.D. 1999).

Opinions

GILBERTSON, Justice (on reassignment).

[¶ 1.] Mitchell Vilhauer (Vilhauer) was injured after being struck in the face by a gate while working at the Corn Palace Stampede. Vilhauer brought suit against defendants Horsemens’ Sports, Inc. (Horsemens’ Sports), Corn Palace Stampede, Inc. (Stampede), Ray Henderson (Henderson), Sutton Rodeos, Inc. (Sutton), and Mark Barnett, South Dakota Attorney General, alleging numerous counts of negligence. Defendants asserted the defense of immunity provided by SDCL 42-11-2. The trial court found SDCL 42 — 11—1 (6)(e) violated Article VI, Section 20 of the South Dakota Constitution. Due to the importance of this constitutional question we granted Horsemens’ Sports’ petition for an intermediate appeal. We now reverse.

FACTS AND PROCEDURE

[¶ 2.] Horsemens’ Sports owns the land in Mitchell, South Dakota where the Corn Palace Stampede is held. Stampede sponsors this annual rodeo and Sutton provides the stock. Henderson designed the gate. In his spare time, Vilhauer worked as a laborer at rodeos. He had worked at approximately eighty rodeos prior to this incident.

[¶ 3.] On July 16, 1994, Vilhauer was assigned to work the saddle bronc event at the Corn Palace Stampede. Following each individual saddle bronc event, the horse is led out of the main arena and into a catch pen. At the time of the incident, Henderson was operating the gate of the catch pen. After the horse is allowed into the catch pen, the horse enters a stripping chute where the saddle and halter are removed. Two sliding gates control this stripping chute, one toward the catch pen and the other away from the arena. Vil-hauer’s duty was to open and close the small gate leading into the stripping chute.

[¶ 4.] While other workers were removing the saddle and halter from the horse in the stripping chute, Vilhauer walked over toward the closed gate to see when the next horse was approaching. This gate was not normally opened or closed during the saddle bronc event and was used to form one of the fences making up the catch pen leading into the stripping chute.

[¶ 5.] When the next saddle bronc left the main arena and entered the catch pen, it ran into the gate. The gate popped open, striking Vilhauer in the face and causing personal injuries. Vilhauer does not know why the gate popped open.

[¶ 6.] Vilhauer filed suit on December 20, 1995, against the defendants, alleging a number of negligence counts. In addition, Vilhauer asked the court to declare SDCL ch 42-11 unconstitutional. The defendants raised the defense of immunity provided by SDCL 42-11-2. All of the parties moved for summary judgment. On January 30, 1998, the trial court issued a [527]*527declaratory judgment and order denying motions for summary judgment. Among other things, this order declared that SDCL 42 — 11—1 (6)(e) violated Article VI, Section 20 of the South Dakota Constitution commonly referred to as the “open courts” provision. Horsemens’ Sports appeals raising the following issue:

Did the circuit court err by declaring SDCL 42 — 11—1 (6)(e) unconstitutional.

STANDARD OF REVIEW

[If 7.] Our review of the constitutionality of a statute is de novo. Green v. Siegel, Barnett & Schutz, 1996 SD 146, ¶ 7, 557 N.W.2d 396, 398 (citing Kyllo v. Panzer, 535 N.W.2d 896, 897 (S.D.1995)).

ANALYSIS AND DECISION

[¶ 8.] Did the circuit court err in declaring SDCL 42-ll-l(6)(e) unconstitutional.

[¶ 9.] Article VI, Section 20 of the South Dakota Constitution provides: “All courts shall be open, and every man for an injury done him in his property, person or reputation, shall have remedy by due course of law, and right and justice, administered without denial or delay.”

[¶ 10.] SDCL ch 42-11 pertaining to equine activities, appears to be a legislative response to the difficulties experienced by rodeos and their sponsors due to liability claims and the cost of insurance. Whether gigantic leaps in the cost of insurance coverage are justified to offset increased claims has been the subject of substantial debate both in the judicial and legislative arenas of this state. See generally Matter of Cert. of Questions of Law (Knowles), 1996 SD 10, ¶¶ 56-70, 544 N.W.2d 183, 195-99.

[¶ 11.] However, in analyzing the constitutionality of statutes partially limiting liability we have consistently held:

Where the constitutional validity of a statute depends upon the existence of facts, courts must be cautious about reaching a conclusion respecting them contrary to that reached by the legislature; and if the question of what the facts establish be fairly debatable one, it is not permissible for the judge to set up his opinion in respect of it against the opinion of the lawmaker. Radice v. New York, 264 U.S. 292, 294, 44 S.Ct. 325, 326, 68 L.Ed. 690, 694 (1924).

Wegleitner v. Sattler, 1998 SD 88, ¶ 30, 582 N.W.2d 688, 697 (quoting Knowles, 1996 SD 10 at ¶ 67, 544 N.W.2d at 197).

[¶ 12.] The errors committed by the trial court in arriving at its conclusion are twofold. First, it failed to construe the entire chapter of SDCL ch. 42-11, but instead improperly examined SDCL 41 — 11—1 (6)(e) in isolation. Second, it failed to consider the proper parameters of Article VI, Section 20.

[¶ 13.] Horsemens’ Sports provided the rodeo grounds and thus qualified as an “equine activity sponsor” under SDCL 42-11-1(4). Vilhauer was a “person assisting a participant or show management,” in a rodeo or “equine activity” pursuant to SDCL 42-11-1(1). As such, SDCL 42-11-2 granted the following protection: “[n]o equine activity sponsor ... or any other person, is liable for an injury to ... a participant resulting from the inherent risks of equine activities.” Thus, Horse-mens’ Sports was able to invoke the protection of SDCL 42-ll~l(6)(e), which via SDCL 42-11-2 provided a limited form of partial immunity for the following activity:

The potential of a participant to act in a negligent manner that may contribute to injury to the participant or others, such as failing to maintain control over the animal or not acting within the participant’s ability.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Espinoza v. Fowler
D. South Dakota, 2023
Stengle v. The Walgreen Company
D. South Dakota, 2021
Fluth v. Schoenfelder Constr., Inc.
2018 SD 65 (South Dakota Supreme Court, 2018)
State v. Berget
2014 SD 61 (South Dakota Supreme Court, 2014)
Dakota Systems, Inc. v. Viken
2005 SD 27 (South Dakota Supreme Court, 2005)
Cleveland v. BDL Enterprises, Inc.
2003 SD 54 (South Dakota Supreme Court, 2003)
Purdy v. Fleming
2002 SD 156 (South Dakota Supreme Court, 2002)
Olson-Roti v. Kilcoin
2002 SD 131 (South Dakota Supreme Court, 2002)
Hancock v. Western South Dakota Juvenile Services Center
2002 SD 69 (South Dakota Supreme Court, 2002)
Cromwell v. Rapid City Police Department
2001 SD 100 (South Dakota Supreme Court, 2001)
Holzer v. Dakota Speedway, Inc.
2000 SD 65 (South Dakota Supreme Court, 2000)
Vilhauer v. Horsemens' Sports, Inc.
1999 SD 93 (South Dakota Supreme Court, 1999)

Cite This Page — Counsel Stack

Bluebook (online)
1999 SD 93, 598 N.W.2d 525, 1999 S.D. LEXIS 114, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vilhauer-v-horsemens-sports-inc-sd-1999.