Murphy v. Steeplechase Amusement Co.
166 N.E. 173 (1929)
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Rule of Law:
An individual who voluntarily participates in an activity accepts the dangers that are inherent, obvious, and necessary to that activity, and thus cannot recover for injuries resulting from those dangers.
Facts:
- Steeplechase Amusement Company operated an amusement park in Coney Island, New York.
- The park featured a ride called 'The Flopper,' which was an inclined, moving belt designed to cause passengers to lose their balance and fall.
- The ride's name was displayed over the entrance, and the area was designed with padded walls and flooring to cushion falls.
- The plaintiff, Murphy, and his friends watched other patrons ride 'The Flopper,' observing them tumbling and falling amidst laughter.
- Murphy's companion acknowledged she 'took a chance' when deciding to go on the ride.
- After his companion got on, Murphy stepped onto the moving belt.
- Upon stepping on the belt, Murphy was thrown to the floor and suffered a fractured kneecap.
Procedural Posture:
- Murphy sued Steeplechase Amusement Company in the New York Trial Term (trial court).
- The jury returned a verdict in favor of Murphy, and the court entered judgment for him.
- Steeplechase Amusement Company, as appellant, appealed to the Appellate Division of the Supreme Court of New York (intermediate appellate court).
- The Appellate Division affirmed the trial court's judgment.
- Steeplechase Amusement Company, as appellant, appealed to the Court of Appeals of New York (the state's highest court).
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Issue:
Does an operator of an amusement park ride have a legal duty to protect a patron from injuries caused by a risk that is obvious, necessary, and inherent to that ride?
Opinions:
Majority - Cardozo, Ch. J.
No. A person who understands and voluntarily accepts an inherent and obvious risk cannot hold another liable for injuries resulting from that risk. The court reasoned that the very purpose of 'The Flopper' was to be unstable and cause falls; this risk was not only obvious but was the source of the amusement. The name of the ride, as well as the sight of other patrons falling, provided ample warning of the inherent dangers. Under the principle of 'volenti non fit injuria' (to a willing person, injury is not done), Murphy assumed the risk of falling, which was the exact hazard that was invited and foreseen. The court distinguished this from cases involving obscure, unobserved, or unreasonably severe dangers, finding that a simple fall was an expected outcome of such an activity.
Dissenting - O'Brien, J.
Yes. The dissent, without providing its own reasoning, would have found the amusement park liable on the authority of a prior case, Tantillo v. Goldstein Brothers Amusement Co.
Analysis:
This case is a foundational decision in tort law establishing the doctrine of primary assumption of risk. It clarifies that a defendant has no duty to protect a plaintiff from risks that are inherent in and fundamental to an activity, so long as those risks are obvious and voluntarily confronted. The ruling has a significant impact on cases involving recreational activities and sports, limiting the liability of operators for injuries that are a natural consequence of the activity. Future courts will use this precedent to distinguish between inherent risks (which are assumed) and unassumed risks created by the defendant's negligence, such as faulty equipment or concealed dangers.
