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Keywords

lawsuitdefendantnegligenceliabilitycomplianceduty of care
plaintiffdefendantnegligencewillcomplianceduty of care

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Sciarrotta v. Global Spectrum, 194 N.J. 345, 944 A.2d 630

Facts

Denise Sciarrotta attended a professional hockey game at the Sovereign Bank Arena, primarily to watch her daughter sing the National Anthem. She was seated in the stands, above the Plexiglas protective barrier, and outside the netting areas behind the goals. During the warm-up period, an unidentified player shot a puck that struck the goalpost and then hit Sciarrotta, causing injury. She subsequently filed a personal injury lawsuit against the arena operators and teams, claiming negligence for failing to provide a safe environment.

On January 4, 2003, plaintiff Denise Sciarrotta attended a professional hockey game between the Trenton Titans and the Johnstown Chiefs at the Sovereign Bank Arena in Trenton. However, her true 'purpose for being at the game was to watch her daughter sing the National Anthem.' Plaintiff was seated in the stands, six or seven rows from the ice. Vertically, she was located above the Plexiglas protective barrier mounted on the side boards that surround the ice rink and, horizontally, she was outside the areas of the rink surrounding the goals that also are protected by netting that extends above the Plexiglas. During the warm-up period preceding the game, when each team had as many as twenty-five pucks in use, an unidentified player took a practice shot at the goal that struck a goalpost and caromed above the Plexiglas, striking and injuring plaintiff.

Issue

Did the arena operator have a duty to warn spectators of the risk of injury from pucks leaving the ice during the warm-up period?

Did the arena operator have a duty to warn spectators of the risk of injury from pucks leaving the ice during the warm-up period?

Rule

The limited-duty rule applies to sports venues regarding the specific peril of objects leaving the field of play that may injure spectators. It requires that sports venue owners or operators provide sufficient screened seating for spectators who may reasonably desire it and ensure protection in the most dangerous sections of the stands. This rule governs the duty of care owed to spectators during all activities on the field of play, including warm-up periods.

Analysis

The court determined that the limited-duty rule applies to the warm-up period, rejecting the notion that a heightened duty of care is warranted due to the increased number of pucks on the ice. The operator had provided adequate protective measures, including netting in the most dangerous areas. Since Sciarrotta was seated in an area that was not deemed to be at high risk and did not request a different seat, the operator fulfilled its duty of care.

We conclude that the limited duty rule applies to all activities on the field of play, including pre-game warm-ups. We further conclude that the limited duty rule itself does not encompass a separate duty to warn of the peril of objects leaving the field of play. Thus, if a sports venue owner or operator complies with the limited duty rule, it has satisfied its duty of care to patrons in the stands and, in those circumstances, no action in negligence will lie for the peril of objects leaving the field of play.

Conclusion

The Supreme Court reversed the Appellate Division's judgment and reinstated the Law Division's ruling, concluding that the arena operator had no duty to warn Sciarrotta of the risks associated with pucks during the warm-up period.

The judgment of the Appellate Division is reversed, and the judgment of the Law Division dismissing plaintiff's complaint with prejudice is reinstated.

Who won?

The defendants, including the arena operator and hockey teams, prevailed in the case. The court found that they had complied with the limited-duty rule by providing adequate protective seating and that Sciarrotta's injury occurred in an area where the operator had no additional duty to warn. The court emphasized that the limited-duty rule applies uniformly to all activities on the field of play, including warm-ups, and that the operator's compliance with safety measures absolved them of liability.

The defendants, including Global Spectrum and the hockey teams, prevailed because they demonstrated compliance with the limited duty rule, which requires providing adequate protection for spectators. The court found that the operator had fulfilled its duty by providing netting in the most dangerous areas and that Sciarrotta's injury occurred in a location where she had not requested additional protection.

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