Jones v. Three Rivers Management Corp.

Rule of Law:

The 'no-duty' rule, which limits a baseball stadium operator's liability for injuries to spectators from risks inherent to the game like batted balls, does not apply to injuries that occur in areas of the stadium where patrons are not expected to be exposed to such risks, such as an interior concourse.

Facts:

• On July 16, 1970, the inaugural day of Three Rivers Stadium, Evelyn M. Jones was a patron at the facility.
• The stadium contained an interior concourse behind the right field seating area, which featured large openings in the wall allowing pedestrians to look out onto the playing field.
• Jones was standing in this concourse and approached one of the openings to view the field, where some activity was occurring, but she was not aware that batting practice had begun.
• After looking at the field, Jones turned away from the opening to walk back toward a different concourse.
• Almost immediately after turning away from the field, she heard a shout of 'Watch!' and was struck in the eye by a batted ball as she turned back toward the field.
• Jones was a baseball fan familiar with the Pirates' former stadium, Forbes Field, where patrons in the concourses were not exposed to batted balls.

Procedural Posture:

• Evelyn M. Jones sued Pittsburgh Athletic Company, Inc. and Three Rivers Management Corporation in the Court of Common Pleas of Allegheny County (trial court).
• A jury returned a verdict in favor of Jones, awarding her $125,000.
• The trial court denied the defendants' motions for judgment notwithstanding the verdict.
• The defendants (as appellants) appealed to the Superior Court of Pennsylvania (an intermediate appellate court).
• The Superior Court reversed the trial court's judgment, finding Jones had failed to establish a prima facie case of negligence.
• Jones (as appellant) was granted an allowance of appeal to the Supreme Court of Pennsylvania (the state's highest court).