Brown v. San Francisco Ball Club, Inc.
222 P.2d 19, 99 Cal. App. 2d 484, 1950 Cal. App. LEXIS 1733 (1950)
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Rule of Law:
A baseball stadium operator discharges its duty of care to spectators by providing a sufficient number of screened seats for those who may reasonably be expected to request them. A spectator who voluntarily chooses to occupy an unscreened seat assumes the common, inherent, and obvious risk of being struck by a batted or thrown ball.
Facts:
- Ms. Brown, a 46-year-old woman, attended a professional baseball game at Seals' Stadium as a guest of friends who purchased tickets for seats in an unscreened section near the first-base line.
- The stadium, owned by the San Francisco Ball Club, Inc., had approximately 5,000 screened seats behind home plate and over 13,000 unscreened seats.
- Patrons could choose which section they wanted to sit in, and tickets were sold at separate, clearly marked windows for each section.
- On the day of the game, attendance was about 5,000, and there were many vacant seats available in all sections, including the screened area.
- Brown had very limited prior experience with baseball, having only seen one game years before from a distance.
- About an hour after arriving, while players were changing sides, Brown was struck by an object, assumed to be a baseball, and sustained serious injury.
Procedural Posture:
- Plaintiff Brown sued defendant San Francisco Ball Club, Inc., in a California trial court for damages from personal injuries.
- At the conclusion of the trial, the court granted the defendant's motion for a directed verdict in its favor.
- The trial court entered a judgment for the defendant.
- The plaintiff's motion for a new trial was denied by the trial court.
- The plaintiff, as appellant, appealed the judgment and the denial of the motion for a new trial to the California Court of Appeal, First District.
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Issue:
Is the owner and operator of a baseball stadium liable for injuries sustained by a spectator who is struck by a baseball while voluntarily occupying an unscreened seat, even if the spectator is unfamiliar with the game of baseball and its inherent risks?
Opinions:
Majority - Wood, J.
No. The owner of a baseball stadium is not liable because a spectator who voluntarily sits in an unscreened seat assumes the risk of being hit by a ball, a danger that is inherent to the game. The operator's duty of care is fulfilled by providing an adequate number of screened seats for patrons who desire them. The court reasoned that the risk of being hit by a baseball is a matter of 'common knowledge' and is obvious to any reasonable person. Appellant's personal ignorance of the game does not excuse her from this standard, as she was a mature adult who could have observed the inherent risks during the hour she was at the game before the accident. Citing precedents like Quinn v. Recreation Park Assn., the court affirmed that when a stadium provides a choice between screened and unscreened seats and offers enough screened seats to meet reasonable demand, spectators who choose the unscreened areas knowingly accept the associated risks and are precluded from recovering damages for such injuries.
Analysis:
This decision solidifies the 'Baseball Rule' in tort law, a specific application of the assumption of risk doctrine. It establishes an objective standard for spectator awareness, holding that the risk of being hit by a ball is so inherent and obvious that a spectator's subjective ignorance of the danger is not a defense. This precedent significantly limits the liability of stadium owners, provided they meet the duty of offering a reasonable number of protected seats. Consequently, it places the primary responsibility on the spectator to assess the risks and choose their seating location accordingly, making it very difficult for injured patrons in unscreened areas to succeed in negligence claims.
