Akins v. Glens Falls City School District, 53 N.Y.2d 325 (1981)

The owner of a baseball field fulfills its duty of reasonable care to spectators by providing screening for the area behind home plate that is sufficient to protect as many spectators as may reasonably be expected to desire such seating during an ordinary game.

Summary

The plaintiff, while watching a high school baseball game from an unscreened area along the third base line, was struck by a foul ball and injured. She sued the school district, alleging negligence for failing to provide adequate screening. The New York Court of Appeals reversed a jury verdict in favor of the plaintiff, holding that the school district fulfilled its duty of care by providing adequate screening behind home plate, the area of greatest danger. The court emphasized that a baseball field owner is not an insurer of spectator safety but must exercise reasonable care, and that providing complete screening of the entire field is not required.

Facts

The plaintiff attended a high school baseball game at a field owned by the defendant school district. The field had a backstop 24 feet high and 50 feet wide behind home plate. Two three-foot chain link fences ran along the base lines from the backstop. The plaintiff chose to stand behind the three-foot fence along the third base line, approximately 60 feet from home plate. She was struck in the eye by a foul ball about ten minutes after arriving, suffering serious injury.

Procedural History

The plaintiff sued the school district for negligence. The trial court entered judgment on a jury verdict finding the school district 65% at fault and the plaintiff 35% at fault. The Appellate Division affirmed. The New York Court of Appeals reversed the Appellate Division’s order and dismissed the complaint, holding that the school district had fulfilled its duty of care as a matter of law.

Issue(s)

Whether the owner of a baseball field is liable for injuries sustained by a spectator struck by a foul ball while standing in an unscreened section of the field, when the owner has provided protective screening for the area behind home plate.

Holding

No, because the proprietor of a baseball park need only provide screening for the area of the field behind home plate where the danger of being struck by a ball is the greatest, and that screening must be sufficient to provide adequate protection for as many spectators as may reasonably be expected to desire such seating in the course of an ordinary game.

Court’s Reasoning

The court stated that a baseball field owner is not an insurer of spectator safety but must exercise “reasonable care under the circumstances.” It acknowledged that many spectators prefer unobstructed views and that owners have a legitimate interest in catering to these preferences. The court adopted the majority rule that an owner must screen the most dangerous section of the field (behind home plate) and provide sufficient screening for those reasonably anticipated to desire protected seats. The court emphasized the practical realities of the sport, stating, “many spectators attending such exhibitions desire to watch the contest taking place on the playing field without having their view obstructed or obscured by a fence or a protective net.” The court found that the school district provided adequate protection behind home plate, and thus could not be liable for failing to provide additional screening along the baselines. The Court distinguished this situation from cases where the adequacy of the screening behind home plate is in question. The court emphasized that it must make a threshold determination of whether the plaintiff has presented adequate evidence to support a favorable jury verdict, and found that the school district had fulfilled its duty of reasonable care as a matter of law. As stated in the opinion, “where a proprietor of a ball park furnishes screening for the area of the field behind home plate where the danger of being struck by a ball is the greatest and that screening is of sufficient extent to provide adequate protection for as many spectators as may reasonably be expected to desire such seating in the course of an ordinary game, the proprietor fulfills the duty of care imposed by law and, therefore, cannot be liable in negligence.”