Stephen Schafer v. Aspen Skiing Corporation

Citations: 742 F.2d 580; 1984 U.S. App. LEXIS 19108Docket: 83-2578

Court: Court of Appeals for the Tenth Circuit; August 29, 1984; Federal Appellate Court

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In the case of Stephen Schafer v. Aspen Skiing Corporation, the United States Court of Appeals for the Tenth Circuit addressed an appeal regarding a skiing accident that occurred on February 28, 1980. The plaintiff filed the lawsuit on March 1, 1983, seeking damages, but the trial court dismissed the case, ruling it was barred by Colorado's three-year statute of limitations under the Colorado Ski Safety Act of 1979. The plaintiff argued his claim was based on common law negligence, which he believed should be subject to a six-year statute of limitations. However, the court emphasized that the nature of the right sued upon, rather than the form of action, determines the applicable statute of limitations. It concluded that the specific provisions of the Ski Safety Act, which governs claims related to skiing injuries, take precedence over the general negligence statute. The court affirmed the trial court's dismissal, clarifying that while the act limits the time to bring claims, it does not abolish the substantive viability of common law claims against ski operators.

Section 33-44-111 mandates that a lawsuit must be initiated within three years of the claim for relief arising. The plaintiff's accident occurred on February 28, 1980, and the lawsuit was filed on March 1, 1983, exceeding the three-year limit. The plaintiff contends that the first day should be excluded from the calculation of the limitations period, citing Section 2-4-108, C.R.S., which states that when computing days, the first day is excluded, and the last day is included. However, this statute does not apply here since Section 33-44-111 pertains to a period of years, not days or months. Under Colorado law, a cause of action for negligence accrues immediately upon the wrongful act, thus starting the statute of limitations on the date of injury. 

The plaintiff further argues that the term "calendar year," as defined in C.R.S. Sec. 2-4-107, implies that the limitation period began on January 1, 1981, and ended December 31, 1983. However, this interpretation is deemed unreasonable, as Section 33-44-111 explicitly requires that actions must commence within three years following the claim's inception based on the date of injury, not the start of a calendar year. 

Additionally, the plaintiff challenges the constitutionality of Section 33-44-111 under the Equal Protection Clause of the Fourteenth Amendment, and various provisions of the Colorado Constitution, asserting it restricts access to the courts and constitutes special legislation. The determination of these claims hinges on whether the classifications created by Section 33-44-111 align with a legitimate state interest.

Determining the constitutionality of a statute under the equal protection clause involves assessing whether a rational relationship exists between the statute's classification and a legitimate governmental purpose. The standard for this inquiry is relatively relaxed, acknowledging that creating classifications is inherently a legislative task that does not require perfection. In the case of McClanahan v. American Gilsonite, the court dismissed the plaintiff’s claims as barred by the statute of limitations, finding no merit in arguments claiming the statute was unconstitutional. Conversely, in Cudahy Co. v. Ragnar Benson, the court upheld the statute, stating that legislative decisions to grant immunity to certain groups after a set period are not inherently discriminatory or arbitrary. The Colorado Supreme Court, in Yarbro v. Hilton Hotels Corp., affirmed this statute's constitutionality, noting that no fundamental rights or suspect classifications were involved, thus applying a standard of reasonable relation to legitimate state objectives, which was found to be satisfied. The ski industry’s significant contribution to Colorado's economy was recognized as a legitimate state interest, supporting the statute's classification. The court emphasized that legislative determinations regarding occupational classifications are to be respected when based on reasonable grounds. The constitutionality of Section 33-44-111 was ultimately affirmed.