Murphy v Steeplechase Amusement Co. (1929): A summary
Case name & citation: Murphy v Steeplechase Amusement Co. [250 N.Y. 479, 166 N.E. 173 (1929)]
Jurisdiction: Court of Appeals of New York
Plaintiff: Murphy
Defendant: Steeplechase Amusement Co.
What does the case talk about?
Murphy v Steeplechase Amusement Co. is an American case law that speaks that no liability in tort can arise when the plaintiff knows and assumes the risk of an injury.
Facts of the case (Murphy v Steeplechase)
The defendant operated an amusement park in Coney Island, New York.
The plaintiff, a young man, got injured in one of the amusements named “The Flopper”, which challenged the riders to stay upright. It was a movable belt that ran upward on an inclined level and allowed riders to sit or stand on it. The plaintiff fell off the belt, which he described as a sudden jerk, and broke his kneecap.
He brought an action against the defendant for negligence.
The plaintiff contended that the belt was dangerous to life and limb because it stopped and started violently and abruptly and that it was not properly equipped to prevent injuries to people who were using it without being aware of its dangers. He further alleged that it was operated at a high and dangerous rate of speed and without an appropriate railing, guard, or other mechanisms to prevent a fall.
The issue raised before the Court
Was the amusement park liable for damages?
Court’s judgement in Murphy v Steeplechase case
The Court held that the defendant was not liable. It observed that a person who takes part in such a sport accepts the dangers inherent in it so far as they are obvious and necessary. For instance, a fencer accepts the risk of a thrust by his opponent or a spectator at a ball game accepts the chance of being hit by the ball.
The Court further said that a different case would have been there if the dangers inherent in the sport were vague or undetected, or if they were so significant that precautions of some type must have been taken to avoid them.
Because of the movement of the belt, many passengers were unable to keep their footing and were thrown backward or aside. The plaintiff stepped on “The Flopper”, causing him to be jerked and thrown. He could easily perceive the risk that he may trip and fall on the floor. In addition, people anticipated that “The Flopper” would jerk and try to knock them over. Because as implied by the name of the ride, “The Flopper”, it was an essential element of the nature of the ride itself. The ride was such that it challenged the riders to stay on it.
The reasoning behind the decision
Chief Judge Benjamin Cardozo applied the common law doctrine “volenti non fit injuria” which means that: “to a willing person, injury is not done”.
In the instant case, the plaintiff knew that he was subjecting himself to a risk of being fallen when he stepped on the moving belt and it was reasonably foreseeable. Thus, no injury can be said to be caused to a person who knows and assumes the risk beforehand.
The concept of the ride was quite obvious, and there were no hidden surprises.
A similar case
Hall v Brooklands Auto Racing Club [1933] was another case where a similar decision was taken by the Courts. A spectator at a motor car race at Brooklands was injured in an accident between two cars on the racing track. The Courts decided that the defendants (the owners of the racing track) were not liable since the plaintiff (the spectator) had impliedly undertaken the risk of such injury being inherent in the game.
List of references:
- https://www.ctdt.co.in/doi/CTDT/pdf/10.5005/jp-journals-10055-0012
- http://guweb2.gonzaga.edu/~dewolf/torts/fall03/text/Chap05.pdf
- https://www.courts.ca.gov/opinions/archive/B282414M.PDF
- https://www.cali.org/sites/default/files/Dec212015FINAL_Johnson_Torts_Cases_and_Context_Volume_1.pdf
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