Boyer v. Iowa High School Athletic Association
152 N.W.2d 293, 1967 Iowa Sup. LEXIS 827, 260 Iowa 1061 (1967)
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Rule of Law:
The doctrine of res ipsa loquitur applies when an injury is caused by an instrumentality under the defendant's exclusive control and management, and the occurrence is such that it would not happen in the ordinary course of things if reasonable care had been used, thereby permitting an inference of negligence without requiring proof of specific acts of negligence.
Facts:
- Plaintiff, a paid spectator, attended a tournament basketball game at Roosevelt Junior High School fieldhouse in Mason City.
- The tournament was under the management, supervision, and direction of defendant, Iowa High School Athletic Association, through a written contract with the school.
- Plaintiff sat on the top row of a 16-foot long, seven-row high section of wood and steel bleachers.
- Near the end of the close and exciting game, spectators in front of plaintiff stood up on the seats or footrests, causing plaintiff and those with her to also stand to see the game's finish.
- As the game ended and spectators began to leave, the section of bleachers occupied by plaintiff and others suddenly collapsed or folded back toward the wall.
- Plaintiff and Mr. Garland were thrown onto the floor, and plaintiff's husband was left hanging by one foot, head down, resulting in plaintiff's injuries.
- The bleachers were regularly pulled out and pushed back for use two to four times a week, a process requiring three men.
- Only the one section of bleachers collapsed, and there was no evidence that any part of the bleachers was broken or out of place.
Procedural Posture:
- Plaintiff sued defendant in state trial court for personal injuries, pleading two counts: specific acts of negligence and negligence under the doctrine of res ipsa loquitur.
- The trial court ruled there was no evidence to support the charges of specific negligence and withdrew them from jury consideration.
- The case was submitted to the jury solely on the doctrine of res ipsa loquitur.
- The jury returned a verdict in favor of the plaintiff.
- Defendant appealed the judgment on the jury verdict to the Supreme Court of Iowa.
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Issue:
Does the doctrine of res ipsa loquitur apply to allow an inference of negligence when bleachers under the defendant's general control collapse during an athletic event, even without specific evidence of a defect or the precise cause of the collapse?
Opinions:
Majority - Garfield, C. J.
Yes, the doctrine of res ipsa loquitur applies to permit an inference of negligence when bleachers under the defendant's control collapse during an athletic event. The court found that the two foundation facts for res ipsa loquitur were met: (1) the bleachers were under the exclusive control and management of the defendant, and (2) the occurrence (bleachers collapsing) is such that in the ordinary course of things it would not happen if reasonable care had been used. The contract between the school and the defendant clearly placed the gymnasium, equipment, and personnel under the defendant's management, supervision, and direction for the tournament's duration, making the defendant the tenant or possessor responsible for the bleachers. The court rejected arguments that evidence of the cause was equally accessible to the plaintiff (noting an injured person's primary concern is treatment, not investigation) and that spectator movement caused the collapse (deeming such a conclusion speculative and emphasizing the defendant's burden to rebut the inference of negligence). The court affirmed that the introduction of evidence of specific negligence does not deprive a plaintiff of the right to have the res ipsa doctrine submitted to the jury.
Concurring - Becker, J.
Yes, I concur in the result that the judgment for the plaintiff should be affirmed. However, I believe it is unnecessary and unwise to continue clinging strictly to the 'exclusive control' doctrine as an indispensable prerequisite for applying res ipsa loquitur. Many authorities, including the Restatement, Second, Torts, and Harper and James, suggest that exclusive control is merely one factor to establish responsibility. The more essential question is whether the probable cause of the accident is one for which the defendant was under a duty to anticipate or guard against, or if the evidence provides a rational basis for concluding that the defendant was responsible for any negligence connected with it. Rawlings, J., joins in this special concurrence.
Analysis:
This case significantly clarifies and reinforces the application of res ipsa loquitur in premises liability and event management contexts. By interpreting 'exclusive control' broadly to include general management and supervision established by contract, and by affirming that the underlying reason for the rule (evidence accessibility) is not an indispensable requirement, the court makes it more feasible for injured plaintiffs to bring claims without needing to pinpoint the exact mechanical failure. This ruling expands the scope of res ipsa loquitur, allowing juries to infer negligence when a normally safe instrumentality malfunctions, thereby shifting the burden to the defendant to demonstrate they exercised reasonable care, particularly in situations where public safety is at stake.
