Maddox v. City of New York, 66 N.Y.2d 270 (1985)
A professional athlete who continues to participate in a sporting event despite being aware of a dangerous condition of the playing field assumes the risk of injury as a matter of law.
Summary
Plaintiff, a professional baseball player, sued the City of New York and the Metropolitan Baseball Club after sustaining a knee injury when he slipped on a wet and muddy baseball field. The New York Court of Appeals held that by continuing to play despite knowing the field’s hazardous condition, the plaintiff had assumed the risk of injury. The court emphasized that the plaintiff’s awareness of the wet and muddy conditions, coupled with his decision to keep playing, constituted implied assumption of risk, barring his recovery. The court distinguished the case from situations where the risk was unknown or enhanced by the defendant’s negligence.
Facts
The plaintiff, a New York Yankees outfielder, was injured at Shea Stadium (Yankees’ temporary home during renovations) when he slipped and fell in the ninth inning of a game. He attributed the fall to wet and muddy conditions on the field. The plaintiff had noticed the wetness and puddling and complained to the grounds crew. He later testified that his foot got stuck in a mud puddle. The previous night’s game had been cancelled due to the weather. The plaintiff sustained a severe knee injury that ended his career.
Procedural History
The plaintiff sued the City of New York (owner of Shea Stadium), the Metropolitan Baseball Club (lessee), the general contractor, architect, and consulting engineer. After depositions, several defendants moved for summary judgment based on assumption of risk. Special Term denied the motions. The Appellate Division reversed, granting summary judgment to the defendants. The New York Court of Appeals affirmed the Appellate Division’s decision.
Issue(s)
Whether a professional baseball player, injured due to a known dangerous condition of the playing field, is barred from recovery by the doctrine of assumption of risk?
Holding
Yes, because the plaintiff, as a professional athlete, was aware of the wet and muddy condition of the field and the potential risk of injury, and his continued participation in the game constituted assumption of risk as a matter of law.
Court’s Reasoning
The court reasoned that the plaintiff’s deposition testimony established his awareness of the dangerous condition and the risk it posed. The court distinguished between express and implied assumption of risk, finding that the plaintiff’s case involved implied assumption of risk based on his conduct. The court emphasized that assumption of risk applies to any open and obvious condition inherent in the activity. The court rejected the argument that the single standard of reasonable care established in Basso v. Miller nullified assumption of risk as a defense. The court also stated “That the assumption doctrine ‘applies to any facet of the activity inherent in it and to any open and obvious condition of the place where it is carried on’”.
The court further clarified that awareness of risk is to be assessed against the background of the skill and experience of the plaintiff, imputing a higher degree of awareness to a professional athlete. “It is not necessary to the application of assumption of risk that the injured plaintiff have foreseen the exact manner in which his or her injury occurred, so long as he or she is aware of the potential for injury of the mechanism from which the injury results.” The court rejected the argument that the risk was enhanced by the failure to install proper drainage, noting that the plaintiff was aware of the mud and water. Although assumption of risk is generally a jury question, the court found that summary judgment was appropriate because the plaintiff’s own testimony established the defense, and he failed to present evidence that he was compelled to play despite the danger.