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Keywords

lawsuitplaintiffdefendantnegligenceappealmotionsummary judgmentduty of caremotion for summary judgment
defendantnegligenceliabilityappealmotionsummary judgmentwillduty of caremotion for summary judgment

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Turcotte v. Fell, 68 N.Y.2d 432, 502 N.E.2d 964, 510 N.Y.S.2d 49

Facts

Professional jockey Ronald J. Turcotte was injured during a race at Belmont Park when his horse clipped the heels of another horse, causing him to fall and suffer severe injuries. Turcotte, who had extensive experience as a jockey, brought a lawsuit against the other jockey, the horse's owner, and the racetrack owner-operator, alleging negligence. The lower courts dismissed the claims against the jockey and horse owner, affirming that Turcotte had consented to the risks inherent in horse racing. The racetrack owner-operator's motion for summary judgment was denied, leading to cross appeals.

Professional jockey Ronald J. Turcotte was injured during a race at Belmont Park when his horse clipped the heels of another horse, causing him to fall and suffer severe injuries.

Issue

Did the plaintiff jockey consent to relieve the defendant jockey of the legal duty to use reasonable care during the race, and was the racetrack owner-operator liable for negligence?

The issue raised in this appeal is the scope of the duty of care owed to a professional athlete injured during a sporting event.

Rule

In negligence actions involving professional athletes, the scope of the duty of care owed is influenced by the participant's consent to the risks inherent in the sport. If a participant voluntarily engages in an activity and is aware of the risks, they may not hold others liable for injuries resulting from those risks. The duty of care owed by co-participants and facility owners is limited to avoiding reckless or intentional conduct.

If a participant makes an informed estimate of the risks involved in the activity and willingly undertakes them, there can be no liability in negligence action if participant is injured as result of those risks.

Analysis

The court analyzed whether Turcotte, by participating in the race, had consented to the risks associated with horse racing, including the possibility of being bumped by another horse. The court found that Turcotte's extensive experience and prior participation in races indicated he was aware of the inherent dangers. The alleged violation of the foul riding rule did not constitute reckless conduct, as the bumping was a normal incident of racing. Therefore, the court concluded that the other jockey did not breach a duty of care.

The analysis of care owed to participant injured in professional sporting event by coparticipant and by proprietor of facility in which event takes place must be evaluated by considering risks injured participant assumed when he elected to participate in event and how those assumed risks qualified duty of defendant coparticipant and proprietor to him, in negligence action brought by injured participant.

Conclusion

The court affirmed the dismissal of the claims against the jockey and horse owner, ruling that Turcotte had consented to the risks of the race. However, the court reversed the lower court's decision regarding the racetrack owner-operator, granting summary judgment in their favor.

The order should be affirmed as to defendants Fell and Reynolds and reversed as to defendant NYRA, and NYRA's motion for summary judgment should be granted.

Who won?

The prevailing party in this case was the defendants, Jeffrey Fell and David P. Reynolds, as well as the New York Racing Association (NYRA). The court found that Turcotte, by participating in the race, had consented to the risks associated with horse racing, which included the possibility of being bumped by other horses. The court ruled that the defendants did not owe a higher duty of care than to avoid reckless or intentional conduct, and since the actions of the other jockey did not rise to that level, the claims against him and the horse owner were properly dismissed. The racetrack owner-operator was also found not liable as Turcotte had accepted the risks of the track conditions.

The prevailing party in this case was the defendants, Jeffrey Fell and David P. Reynolds, as well as the New York Racing Association (NYRA).

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