Clapman v. New York Yankees, 63 N.Y.2d 669 (1984)

Owners of baseball stadiums have a duty to provide adequately screened seating in the most dangerous areas (behind home plate) and a sufficient number of seats to meet reasonable demand, but they are not insurers of spectator safety from foul balls.

Summary

David Clapman, injured by a foul ball at Yankee Stadium, sued the stadium owner, operator, architect, and vendor concessionaire, alleging negligence in failing to extend protective screening, providing insufficient screened seating, and allowing vendors to obstruct views. The New York Court of Appeals affirmed the lower courts’ grant of summary judgment for the defendants, holding that the stadium had met its duty by providing adequate screening behind home plate and a sufficient number of seats. The court also found that the plaintiff’s claim of obstructed view was contradicted by his own testimony and that the stadium had no duty to prevent vendors from briefly interfering with views.

Facts

David Clapman was seated in the box seat area behind the Yankee dugout at Yankee Stadium during a baseball game. He was struck by a foul ball and sustained personal injuries. Clapman alleged his view was obstructed by vendors moving in the aisles at the time he was struck.

Procedural History

Clapman and his wife sued the stadium owner, its lessee and operator, its architect, and its vending concessionaire. The defendants moved for summary judgment. The lower courts granted the motions for summary judgment in favor of the defendants. The New York Court of Appeals affirmed the lower court’s decision.

Issue(s)

1. Whether the respondents were negligent in not extending the protective screen behind home plate to the area where Clapman was seated?
2. Whether the respondents were negligent in providing insufficient seating behind the existing screen?
3. Whether the respondents were negligent in allowing Clapman’s view of the play to be obstructed by vendors who moved about the aisles during the game?

Holding

1. No, because the stadium owner has a duty to provide adequate screening in the most dangerous areas, and appellants failed to raise an issue of material fact that the stadium failed to do so.
2. No, because the stadium owner has a duty to provide a sufficient number of seats behind the screen to accommodate those who may reasonably be expected to desire such seating, and appellants failed to raise an issue of material fact that the stadium failed to do so.
3. No, because given the location of the vendors and Clapman’s seat, respondents had no duty to ensure that vendors moving about in the stadium did not interfere with Clapman’s view.

Court’s Reasoning

The court relied on the principles established in Davidoff v. Metropolitan Baseball Club and Akins v. Glens Falls City School Dist.. These cases articulate that stadium owners must provide adequate protection in areas where the danger of being hit by projectiles is greatest, specifically behind home plate. The court reasoned that the stadium had met this duty by providing a screen in that high-risk area and providing sufficient seating behind the screen for spectators who wished to be protected. The court also noted that Clapman’s own deposition testimony contradicted his claim that vendors obstructed his view of the ball. The court emphasized that stadium owners are not insurers of spectator safety. The court stated, “Appellants failed to raise any issue of material fact concerning a failure to erect a screen providing adequate protection in the area behind home plate, where the danger of being hit by foul balls is greatest, or to provide sufficient seats behind the screen to accommodate as many spectators as reasonably may be expected to desire such seating. In such circumstances there is no breach of duty by respondents.”