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Keywords

lawsuittortdefendantnegligenceliabilitystatuteprecedentappealtrialsustained

tortplaintiffliabilitystatutetrial

Related Cases

Harris v. University of Michigan Bd. of Regents, 219 Mich.App. 679, 558 N.W.2d 225, 115 Ed. Law Rep. 488

Facts

A university student, a member of the intercollegiate gymnastics team, sustained injuries during a sledding outing while attending an out-of-state competition in Colorado. The student filed lawsuits against the University of Michigan's Board of Regents, its president, athletic director, and gymnastics coach, claiming that the university's athletic department operated for profit and thus was not entitled to governmental immunity. The cases were consolidated, and the trial court granted summary disposition for the university officials based on governmental immunity, leading to the student's appeal.

On March 7, 1990, plaintiff was in Colorado with the University of Michigan's gymnastics team. Between competitions, coach Darden led the team on a sledding outing and provided plastic trash bags for the team to use as sleds. While sledding, plaintiff crashed into a tree at the bottom of the slope and injured his face and head.

Issue

Whether the operation of intercollegiate athletics by a public university constitutes a governmental function that is immune from tort liability under Michigan's governmental immunity statute.

Rule

The operation of intercollegiate athletics is considered a governmental function under Michigan law, which provides immunity from tort liability unless the activity is classified as a proprietary function. A proprietary function is defined as an activity conducted primarily for profit, and the existence of profit does not automatically classify an activity as proprietary if it is normally supported by taxes.

Analysis

The court analyzed whether the university's athletic programs were primarily for profit or educational purposes. It found that intercollegiate athletics is a governmental function, supported by historical precedent and legislative recognition. The court noted that most sports, including gymnastics, operate at a loss and are subsidized by more profitable sports, indicating that profit was not the primary motive. Therefore, the proprietary function exception to governmental immunity did not apply.

Given the broad definition of a governmental function, and in light of the history of intercollegiate athletics at Michigan universities and colleges that has historic support from the Michigan Legislature, we find that intercollegiate athletics is a governmental function for purposes of immunity. [Citations omitted]

Conclusion

The court affirmed the trial court's decision, holding that the university's operation of its athletic programs was a governmental function entitled to immunity from tort liability.

The trial court correctly determined that the university's operation of its athletic program was not a proprietary function, and thus the university was entitled to governmental immunity from plaintiff's claims. [Court's conclusion]

Who won?

The University of Michigan and its officials prevailed in this case. The court upheld the trial court's ruling that the university's athletic programs were governmental functions, thus granting them immunity from the student's claims. The court emphasized that the primary purpose of the athletic programs was educational, not profit-driven, and that the student failed to provide evidence of gross negligence against the individual defendants.

The University of Michigan and its officials prevailed in this case, as the court found that the operation of intercollegiate athletics was a governmental function, thus granting them immunity from the student's claims. The court noted that the athletic programs were primarily educational and not conducted for profit, which was crucial in determining the applicability of governmental immunity.

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