Anderle v. Eagle Point Farms, Inc., 42 N.Y.2d 81 (1977)

A landowner owes a duty of reasonable care to paying guests, which may include taking precautions to protect them from foreseeable risks arising from the property’s layout and activities conducted thereon.

Summary

A five-year-old girl was injured at a mountain resort when she ran into the side of a slowly moving pickup truck on a private road dividing the resort’s recreational facilities. The plaintiffs sued the resort owner and the truck operator. The jury found the resort owner liable, but the Appellate Division reversed, stating that there was no liability because the child was under parental supervision. The Court of Appeals reversed the Appellate Division, holding that the resort owner had a duty to provide a safe environment, and whether the resort breached that duty by creating a potentially hazardous situation with the road separating entertainment from play areas was a question for the jury.

Facts

The Anderle family were paying guests at Eagle Point Farms, a mountain resort. On July 4th, the resort hosted festivities, including a movie and fireworks. These events were located across a private road from the children’s play area. The road was normally free of traffic, and children crossed it frequently. Christine, the five-year-old plaintiff, was running across the road when she ran into the side of a slow-moving pickup truck owned by the resort owner’s son and driven by his daughter, both resort employees. She was injured by the truck’s rear wheel.

Procedural History

The trial court found the resort owner liable for negligence, but acquitted the truck owner and operator. The Appellate Division reversed, dismissing the complaint, finding no liability based on parental supervision. The plaintiffs appealed to the New York Court of Appeals.

Issue(s)

Whether the resort owner had a duty to exercise reasonable care to protect its paying guests, including the infant plaintiff, from foreseeable dangers on its property, and whether the layout of the resort, specifically the private road separating entertainment and play areas, constituted a breach of that duty.

Holding

Yes, because the resort owner’s arrangements foreseeably encouraged the separation of parents from their children, creating a potentially hazardous situation, and the jury should determine whether the resort breached its duty of care.

Court’s Reasoning

The Court of Appeals reasoned that as paying guests, the Anderle family was owed a high level of duty by the resort owner. The court emphasized that it was foreseeable that the resort’s arrangement—separating the movie area from the children’s play area by a road—would encourage parents and children to separate. The court cited recent cases enlarging the duty owed by occupants of land to those upon their premises, including Basso v. Miller. The court stated, “It was foreseeable that entertainment and play facilities, designed to attract users in order to enhance the commercial profitability of the resort premises, might have the very effect created that July Fourth, namely, encouraging separation of the parents from their children.”

The court noted that given the rural mountain setting and the extensive 130-acre tract, a jury could find the resort owner obligated to close off or prevent motor traffic on the road. The infrequency of traffic could lull guests into a false sense of security, especially concerning young children. The court concluded that the case did not turn on whether the child was under immediate parental supervision, as the relaxation in supervision was arguably due to the resort’s deliberate arrangements. The court emphasized that the accident occurred early in the summer season on a festive holiday when the risk of lulling guests into a false security was arguably foreseeable. The question of negligence, therefore, was properly one for the jury. The court directly addressed the foreseeability aspect when it stated “Given the generally rural mountain setting, the extensive 130-acre tract with its variety of buildings and facilities, including a lake, a park, a golf course, and a virtually traffic free private road through the premises, a jury could find that under the circumstances the resort owner would have had the obligation to close off or prevent any motor traffic on the road.”