Waiver, Immunity for Sports Injuries Highlight Pa. Supreme Court Arguments
With one case involving a student who suffered a concussion in his school's gymnasium and another involving a man who drowned during a triathlon, liability for sports-related claims are set to highlight the state Supreme Court's argument session scheduled to begin March 6 in Philadelphia.
March 01, 2018 at 12:10 PM
5 minute read
With one case involving a student who suffered a concussion in his school's gymnasium and another involving a man who drowned during a triathlon, liability for sports-related claims are set to highlight the Pennsylvania Supreme Court's argument session scheduled to begin March 6 in Philadelphia.
A full complement of the Supreme Court is set to hear argument in 12 cases over March 6 and 7. The justices are expected to hear argument on a range of topics, including how appellate courts should review cases when there is little trial court guidance and the ability of police officers to re-enter premises without obtaining a warrant. But, with two sports-related cases, liabilities for entities conducting sports-related activities are set to highlight the session.
Early on March 7, the justices are set to hear argument in Brewington v. City of Philadelphia over whether failing to fully cover a concrete wall in a school's gymnasium with protective matting fits the narrow exception for governmental immunity. The justices specifically agreed to hear argument on whether the Commonwealth Court “impermissibly” broadened that exception when it allowed a student to sue his former school after he struck his head on a concrete wall while running a relay race in his school's gym.
Last year, an en banc panel of the Commonwealth Court ruled that Jarrett Brewington, a former student at the now-closed Walter G. Smith Elementary School, could sue the school for the concussion he sustained. The court had determined that the facts fell under the real property exception to the general rule for governmental immunity under Pennsylvania's Tort Claims Act.
Later on March 7, the justices are also set to hear arguments in Valentino v. Philadelphia Triathlon, which deals with whether the widow of a man who drowned during the Philadelphia Triathlon can sue the event organizers, despite the decedent having signed a waiver assuming all the risks of participating in the event.
The precise question the court agreed to hear argument on focuses on whether “a waiver of liability form, executed solely by the decedent, and stating the signer assumes all risks of participation in a triathlon, also binds his heirs, thereby precluding them from bringing a wrongful death action.”
Last year, an en banc Superior Court panel found that the waiver did in fact bind the man's heirs, and prevented his widow from bringing suit. That decision differed from a ruling a three-judge Superior Court panel made in 2015, which said the surviving spouse, who did not sign the waiver, was not bound by the release.
Superior Court Judge Judith Ference Olson wrote the majority opinion for the more-recent en banc panel. In her ruling, she said the triathlete's decision to transfer liability to himself by signing the waiver eliminated any possibility of tortious conduct on the part of the defendant.
According to court records, the Philadelphia Triathlon consisted of a half-mile swim, a 15.7-mile bicycle race, and a 3.1-mile run. As part of the registration, each participant needed to pay a fee and sign a waiver and release form. Derek Valentino registered for the event in January 2010. Valentino, court records said, entered the water for the swimming portion of the event at 8:30 a.m. June 26, 2010, but he did not complete the race, and his body was found in the Schuylkill River the following day.
The plaintiffs argued that Pisano v. Extendicare Homes stood for the principle that a waiver did not extinguish third-party rights. But Olson said Pisano was concerned only with civil procedure and venue.
The justices are set to hear arguments on whether a police officer's re-entry to a residence after initially entering under exigent circumstances constitutes one continual search.
In Commonwealth v. Wilmer, the state Superior Court ruled in December 2016 to uphold a Cumberland County judge's denial of defendant Ashley Wilmer's motion to suppress.
Wilmer had sought to block admission into evidence of two pieces of marijuana paraphernalia recovered by a Pennsylvania state trooper when he re-entered Wilmer's sorority house to complete paperwork related to items that were damaged during his initial entry to the home under exigent circumstances.
Late on March 7, the justices are also set to hear arguments in Dolan v. Hurd Millwork, in which the Superior Court found it was forced to vacate a nearly $750,000 judgment and order a new trial because the trial judge who rendered the verdict failed to adequately explain his reasoning and had retired from the bench.
The question before the Supreme Court focuses on what an appellate court's proper role should be when reviewing a bench verdict if the trial judge is no longer available to explain the reasoning behind it.
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