Patton v. United States Rugby Football
381 Md. 627, 2004 Md. LEXIS 308, 851 A.2d 566 (2004)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
An organizer of a voluntary, amateur outdoor sporting event does not owe a special legal duty to protect adult participants or spectators from lightning strikes, as such individuals are generally deemed capable of perceiving natural dangers and are not considered to have ceded control of their safety to the organizers, thus precluding the existence of a 'special relationship' necessary for such a duty.
Facts:
- On June 17, 2000, Robert Carson Patton, II, arrived at playing fields adjacent to Annapolis Middle School to play rugby for the Norfolk Blues Rugby Club in a tournament.
- Donald Lee Patton, Robert's father, accompanied him to the tournament as a spectator.
- Robert and Donald, along with other participants and spectators, placed their equipment and belongings under a row of trees adjacent to the playing fields.
- Rugby matches began around 9:00 a.m. on a warm, muggy day, with a weather forecast for possible thunderstorms.
- Prior to the start of Robert's match, a thunderstorm passed through the area, and at the beginning of the match, rain commenced, and lightning could be seen and thunder heard directly overhead. The National Weather Service had issued a thunderstorm 'warning'.
- Kevin Eager, a volunteer referee, continued Robert's match despite increasing rain, deteriorating weather conditions, and lightning flashes directly overhead, even as other matches at the tournament ended.
- Robert's match was stopped just prior to its normal conclusion.
- Upon termination of the match, Robert and Donald fled the playing fields to the area under the trees to retrieve their possessions, and as they began to exit, both were struck by lightning. Donald died, and Robert sustained personal injuries.
Procedural Posture:
- Robert and various other members of the Patton family filed a lawsuit in the Circuit Court for Anne Arundel County (trial court) against the rugby tournament organizers, referee, and related organizations, alleging negligence.
- Defendants filed Motions to Dismiss, arguing they owed no legal duty to Robert and Donald Patton.
- On July 10, 2003, the Circuit Court granted the motions to dismiss, finding that the defendants did not owe a duty of care to Robert or Donald Patton.
- The Patton family appealed the Circuit Court's dismissal.
- The Court of Appeals of Maryland, on its own initiative and before the appeal could be decided by the Court of Special Appeals (intermediate appellate court), issued a writ of certiorari to determine whether any of the defendants owed a legal duty under the alleged circumstances.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does an organizer of an amateur outdoor sporting event owe a special legal duty to protect adult participants and spectators from injuries caused by lightning strikes during a thunderstorm?
Opinions:
Majority - Harrell, J.
No, an organizer of an amateur outdoor sporting event does not owe a special legal duty to protect adult participants and spectators from injuries caused by lightning strikes during a thunderstorm. The Court affirmed the Circuit Court's dismissal, holding that the "special relationship" doctrine, which creates a duty to protect, did not apply because Robert and Donald Patton had not ceded control of their safety to the organizers and were not dependent on them. The Court emphasized that for a special relationship to exist, there must be an element of dependence and a ceding of self-control by the injured party. In this case, adult participants and spectators in a voluntary amateur sporting event are free to leave at any time and are capable of perceiving and reacting to changing weather conditions. The Court cited its precedents in Remsburg and Muthukumarana/Fried, which narrowly construe the "special relationship" exception, and found persuasive the reasoning in Dykema v. Gus Macker Enters., Inc., a Michigan case with similar facts. The Court noted that lightning is a universally known danger, and it is unreasonable to impose a duty to protect against a condition readily observable by competent adults.
Concurring - Chief Judge Bell
Chief Judge Bell joined in the judgment only, indicating agreement with the outcome but not necessarily with the majority's reasoning or all parts of the opinion.
Analysis:
This case significantly reinforces the narrow interpretation of the "special relationship" doctrine in Maryland, particularly concerning acts of nature. It clarifies that merely organizing an event where harm is foreseeable is not enough to create a legal duty; there must be an element of dependence and loss of control by the injured party. The decision limits the scope of potential liability for event organizers regarding natural phenomena when participants are competent adults capable of independent judgment and action. Future cases will likely emphasize the voluntary nature of activities and the autonomy of adult participants when considering duty of care for environmental hazards.
