Brown v. San Francisco Ball Club, Inc.
99 Cal. App. 2d 484, 1950 Cal. App. LEXIS 1733, 222 P.2d 19 (1950)
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Rule of Law:
The owner of a baseball stadium has a duty to provide a sufficient number of screened seats for patrons who may reasonably be expected to request them. A spectator who voluntarily chooses to sit in an unscreened seat assumes the risk of being struck by a thrown or batted ball, as this is an open and obvious danger inherent to the sport.
Facts:
- San Francisco Ball Club, Inc. owned and operated Seals' Stadium, which had approximately 5,000 screened seats behind home plate and thousands of unscreened seats along the first and third baselines.
- Patrons decided where to sit and purchased tickets at windows specifically marked for each section.
- Brown, a 46-year-old woman with limited prior experience watching baseball, attended a game as a guest.
- Her party obtained tickets for and sat in an unscreened section near the first-base line.
- At the time of the game, many seats in the screened section were vacant.
- After being at the game for about an hour, while the players were changing sides, Brown was struck and seriously injured by an object presumed to be a baseball.
Procedural Posture:
- Brown filed a lawsuit for personal injuries against the San Francisco Ball Club, Inc. in the trial court.
- At the close of evidence, the trial court granted the defendant's motion for a directed verdict.
- The trial court entered a judgment in favor of the defendant, San Francisco Ball Club, Inc.
- Brown's subsequent motion for a new trial was denied by the trial court.
- Brown (as appellant) appealed the judgment and the denial of the new trial motion to the California District Court of Appeal (an intermediate appellate court).
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Issue:
Does a baseball stadium owner breach its duty of care to a spectator who is injured by a thrown baseball while voluntarily sitting in an unscreened seat, even if the spectator claims ignorance of the risks inherent in the game?
Opinions:
Majority - Wood, J.
No. A baseball stadium owner does not breach its duty of care under these circumstances because a spectator who voluntarily occupies an unscreened seat assumes the risk of injury from thrown or batted balls. The court reasoned that the proprietor's duty is not to insure the safety of patrons, but to exercise ordinary care, which includes providing screened seats for as many patrons as may reasonably be expected to request them. The risk of being struck by a baseball is a well-known hazard inherent to the game. By choosing an unscreened seat when screened seats were available, Brown assumed this risk. The court rejected her claim of ignorance, holding that a mature adult is imputed with the common knowledge of the obvious risks of the sport, or at least should have observed such risks after watching the game for an hour.
Analysis:
This decision solidifies the application of the assumption of risk doctrine, often called the 'Baseball Rule,' in California. It establishes that a stadium owner's duty is limited and is satisfied by providing some screened seating, rather than a duty to warn every patron of obvious dangers. The ruling sets a precedent that a spectator's subjective ignorance of a widely known, inherent risk does not defeat the assumption of risk defense, effectively holding spectators to an objective standard of awareness for dangers associated with the event they choose to attend.
