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Aspinall v. Murrieta Valley Unified School District, Not Reported in Cal.Rptr., 2018 WL 1163182

Facts

William Casey Aspinall suffered a severe concussion during a seven-on-seven touch football drill in a physical education class. The drill was supervised by Erik Even Daarstad, a teacher and junior varsity football coach. Despite instructions to avoid physical play, the drill became aggressive, leading to a collision between Aspinall and a classmate. Aspinall was left unconscious and bleeding, and he later experienced significant health issues, including migraines and memory problems. He sued the school district and Daarstad for negligence and negligent supervision.

William Casey Aspinall suffered a severe concussion when he and a classmate collided while attempting to intercept a football during a drill in a football physical education (P.E.) class.

Issue

Did the District defendants act negligently or recklessly in supervising the football P.E. class, and did their actions contribute to Aspinall's injuries?

Did the District defendants act negligently or recklessly in supervising the football P.E. class, and did their actions contribute to Aspinall's injuries?

Rule

The primary assumption of risk doctrine limits liability in sports-related injuries, stating that defendants do not have a duty to protect participants from inherent risks of the activity. However, they must not increase those risks beyond what is inherent. The court must determine if the defendants engaged in reckless conduct or increased the risk of injury.

The primary assumption of risk doctrine limits liability in sports-related injuries, stating that defendants do not have a duty to protect participants from inherent risks of the activity. However, they must not increase those risks beyond what is inherent.

Analysis

The court found that while the District defendants acted recklessly, their conduct was not a substantial factor in causing Aspinall's injuries. The jury determined that the risks of collision were inherent in the sport of football, and the defendants did not increase those risks. The court also ruled that the exclusion of expert testimony regarding the defendants' conduct was appropriate, as it lacked relevance under the primary assumption of risk doctrine.

The court found that while the District defendants acted recklessly, their conduct was not a substantial factor in causing Aspinall's injuries. The jury determined that the risks of collision were inherent in the sport of football, and the defendants did not increase those risks. The court also ruled that the exclusion of expert testimony regarding the defendants' conduct was appropriate, as it lacked relevance under the primary assumption of risk doctrine.

Conclusion

The court affirmed the jury's verdict in favor of the District defendants, concluding that their actions did not substantially contribute to Aspinall's injuries.

The court affirmed the jury's verdict in favor of the District defendants, concluding that their actions did not substantially contribute to Aspinall's injuries.

Who won?

The Murrieta Valley Unified School District and Erik Even Daarstad prevailed in this case. The jury found that while the defendants acted recklessly, their conduct was not a substantial factor in causing Aspinall's injuries. The court upheld the jury's decision, emphasizing that the inherent risks of football were acknowledged and that the defendants did not increase those risks beyond what was expected in the sport.

The Murrieta Valley Unified School District and Erik Even Daarstad prevailed in this case. The jury found that while the defendants acted recklessly, their conduct was not a substantial factor in causing Aspinall's injuries.

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