Godee v. Illinois Youth Soccer Ass'n
764 N.E.2d 591, 261 Ill. Dec. 976, 327 Ill. App. 3d 695 (2002)
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Rule of Law:
An organization that administers youth sports games on property it does not own or control owes no duty of care to a spectator for an injury sustained on that property, as the organization's undertaking is limited to the participants and the game itself.
Facts:
- Volunteer coaches Mark West and Rob Salazar scheduled a practice soccer game for their youth team.
- Upon finding the original location in use, the coaches moved the game to an unauthorized field at Spring Trail Elementary School.
- Neither the Illinois Youth Soccer Association (IYSA) nor the Northern Illinois Soccer League (NISL) owned or had authorized the use of the field at Spring Trail Elementary.
- The leagues were not advised that the coaches had moved the game to this location.
- Mary Lynn Godee attended her son's practice game at the school field.
- After the game concluded, Godee was walking to the parking lot.
- While walking, Godee slipped and fell into a drainage ditch located on the school's property, causing her to sustain injuries.
Procedural Posture:
- Plaintiff, Mary Lynn Godee, sued defendants, Illinois Youth Soccer Association (IYSA), Northern Illinois Soccer League (NISL), and coaches Mark West and Rob Salazar, in the trial court.
- Defendants moved for summary judgment, arguing they owed no duty of care to the plaintiff.
- The trial court granted summary judgment in favor of all defendants.
- Plaintiff Godee, as the appellant, appealed the trial court's grant of summary judgment to the intermediate appellate court.
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Issue:
Does a youth soccer league or its volunteer coaches owe a duty of care to a spectator who is injured in a drainage ditch on property that the league and coaches do not own, operate, or control?
Opinions:
Majority - Justice Callum
No. A youth soccer league and its coaches do not owe a duty of care to a spectator injured on property they do not own or control. The court determined that under a general negligence theory, the relationship between the defendants and a spectator is too remote to impose a duty to inspect the premises and warn of off-field dangers. Citing Loosier v. Youth Baseball & Softball, Inc., the court found it would be an unreasonable burden and against public policy to require volunteer organizations to ensure the safety of spectators on public property. The court distinguished this from the duty owed to game participants, stating the defendants' undertaking was limited to the administration of the game for the players. Under a premises liability theory, a duty only arises if the defendant possesses and controls the property. Here, like the defendant in Collins v. Mid-America Bag Co., the coaches were merely permissive users (licensees) of the field and did not exercise the requisite control over the entire premises to create a duty to the plaintiff.
Analysis:
This decision clarifies and narrows the scope of duty for volunteer organizations and their agents, like coaches, who utilize public or third-party property. It establishes a clear distinction between the duty owed to participants, who are directly entrusted to the organization's care, and the much more limited duty owed to spectators. The ruling reinforces the principle that liability, particularly premises liability, is fundamentally linked to possession and control of the property. This precedent protects volunteer-run leagues from potentially expansive and burdensome liability for conditions on properties they do not own, maintain, or control, which could otherwise deter such community activities.
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