Morgan State University v. Pamela R. Walker
919 A.2d 21 (2007)
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Rule of Law:
A plaintiff who has knowledge of and appreciates an obvious risk, such as slipping on ice, and voluntarily chooses to confront that risk, has assumed the risk of injury as a matter of law, thereby barring recovery in a negligence action. The voluntariness of the plaintiff's action is judged by an objective standard and is not negated by a plaintiff's personal motivations for confronting the risk.
Facts:
- Between February 16-18, 2003, a heavy snowstorm occurred in Baltimore.
- On February 24, 2003, Pamela Walker drove to Morgan State University (MSU) to visit her daughter and give her money.
- Upon entering the parking lot in front of her daughter's dormitory, Walker noticed she was driving on "crunchy ice and snow."
- Walker parked her car, observing that the ground between her car and the dormitory entrance was covered in snow and ice.
- To be safe, Walker held onto adjacent cars as she walked to the dormitory, which she reached without incident.
- After an hour-long visit, Walker began walking back to her car, again proceeding slowly and holding onto cars for support.
- Upon reaching her own vehicle, Walker lost her footing on the ice, fell, and fractured her leg.
Procedural Posture:
- Pamela Walker sued Morgan State University (MSU) in the Circuit Court for Baltimore City for negligence.
- The Circuit Court (trial court) granted summary judgment in favor of MSU, ruling that Walker had assumed the risk of her injury as a matter of law.
- Walker, as appellant, appealed to the Court of Special Appeals of Maryland (intermediate appellate court).
- The Court of Special Appeals reversed the trial court's judgment, holding that the question of whether Walker's actions were voluntary should be decided by a jury.
- MSU, as petitioner, successfully petitioned for a writ of certiorari from the Court of Appeals of Maryland (the state's highest court).
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Issue:
Does a person who, after observing that a parking lot is covered in snow and ice, proceeds to walk across it to visit a family member, voluntarily assume the risk of falling as a matter of law?
Opinions:
Majority - Greene, J.
Yes, a person who knowingly and voluntarily walks across a snow and ice covered parking lot assumes the risk of falling as a matter of law. The doctrine of assumption of risk bars a plaintiff's recovery when the defendant can show the plaintiff: (1) had knowledge of the risk, (2) appreciated the risk, and (3) voluntarily confronted the risk. The court applies an objective standard to this analysis. Here, Walker's testimony showed she was aware of the ice and appreciated the risk, as evidenced by her cautious behavior. Slipping on ice is a risk any adult is taken to appreciate. Her decision to proceed was voluntary because she was not forced against her will; she had the alternative of turning around and going home. Her motivation to bring her daughter money does not render her actions legally involuntary. Because Walker voluntarily assumed a known risk, any negligence by MSU in failing to clear the lot is superseded and irrelevant.
Analysis:
This decision reinforces Maryland's strict adherence to the doctrine of assumption of risk as a complete bar to recovery in negligence cases. The court clarifies that the 'voluntariness' element is assessed under a stringent objective standard, where the existence of any alternative, including forgoing the activity, renders the choice voluntary. The ruling makes it significantly more difficult for plaintiffs to survive summary judgment in cases involving obvious hazards like ice, as it establishes that a plaintiff's personal motivations for confronting a risk are legally irrelevant. This precedent solidifies that a defendant's duty of care is completely superseded once a plaintiff is found to have assumed the risk.
