Injured High School Track Athlete Hurdles Summary Judgment


Morales v. Beacon City School District (New York)
(Inexperienced High School Track Athlete Injured During Practice After Coach Directed Him to Run Hurdles With Minimal Instruction; Court Denied School’s Summary Judgment Due to Triable Issue of Fact Regarding Increased Risks.)

The plaintiff was a high school track athlete who had minimal experience running hurdles. He claimed that the coach told him to run hurdles, but failed to give him adequate instruction, resulting in his personal injury. Additionally, the athlete contended the hurdle he fell over was not set up properly because the horizontal bar was uneven. The defendant school moved for summary judgment on the grounds that the plaintiff had assumed the inherent risks of injury by participating in this sports activity. The court denied the motion and the school appealed

On appeal, the Court affirmed the ruling, finding that the assumption of the risk doctrine in competitive athletics did not completely bar the plaintiff’s recovery. Despite his participation, the Court indicated that the defendant still owed the plaintiff a duty to avoid unreasonably increasing the inherent risks in the sports activity. Due to the alleged dangerous conditions and the lack of instruction given by the coach, the Court stated that there was a triable issue as to whether the risks were increased.

NOTE: Decisions like this are difficult for schools. Inevitably, coaches will be asked to push students to learn and try new activities. The courts walk a fine line in deciding when a coach does or does not increase the risks inherent in an activity. From a defense perspective, it is difficult to accept that a runner on a track team does not generally assume the risk of falling and suffering personal injury while engaging in all track activities. Having read this opinion, a school is left with the tough task of deciding what is sufficient instruction before encouraging an athlete to try a new activity. In the end, this type of decision may tend to discourage vigorous participation in school organized sports.

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