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King v. Cornell University

Citations: 119 A.D.3d 1195; 990 N.Y.S.2d 329

Court: Appellate Division of the Supreme Court of the State of New York; July 17, 2014; New York; State Appellate Court

Narrative Opinion Summary

This case involves an appeal from a Supreme Court order, which denied the defendant educational institution's motion for summary judgment in a negligence lawsuit. The lawsuit was initiated by the parents of a deceased 19-year-old student who fell to his death in a gorge on campus. The plaintiffs alleged negligence on the part of the institution, claiming their son fell while intoxicated and under the influence of marijuana. The defendant sought summary judgment under General Obligations Law § 9-103, arguing for immunity as the student's actions constituted 'hiking,' a protected recreational activity under the statute. The court, however, determined a factual question existed regarding whether the activity was indeed 'hiking' as defined by the statute. Additionally, the court found that the dangers posed by the gorge were not sufficiently obvious, due to inadequate warning signs and safety measures, thus requiring further examination at trial. Consequently, the order denying summary judgment was upheld, with costs awarded to the plaintiffs, allowing the case to proceed to trial to resolve these factual issues.

Legal Issues Addressed

Adequacy of Warnings and Safety Measures

Application: The court considered whether the warnings and safety measures provided by the defendant were sufficient to alert the decedent to the proximity of the cliff, a matter to be determined at trial.

Reasoning: Consequently, the adequacy of these warnings and safety measures remains a factual issue for trial.

Definition of 'Hiking' in Liability Context

Application: The court addressed the definition of hiking, emphasizing it as traveling through woods on foot, to assess if the decedent’s activity met this characterization.

Reasoning: The decision emphasized that the definition of hiking includes traveling through woods on foot, which the decedent was doing before his fall.

Duty of Care for Landowners

Application: The court examined the landowner's obligation to maintain safe conditions and provide warnings about latent dangers, distinguishing between open and obvious dangers and those that are not.

Reasoning: The court noted that a landowner is obligated to maintain property safely and to warn of latent dangers, but this duty does not cover open and obvious dangers.

Factual Question of Obviousness of Danger

Application: The court identified a factual issue regarding whether the danger presented by the cliff edge was obvious or latent, affecting the landowner’s duty to warn.

Reasoning: However, the court found that the specific conditions at the cliff edge, including the substantial drop-off, were not clearly depicted in the evidence provided, leaving a factual question about whether the hazard was obvious or latent.

Immunity Under General Obligations Law § 9-103

Application: The court evaluated whether the defendant, an educational institution, was entitled to immunity under this law, which protects property owners from liability during recreational activities, by determining if the decedent’s actions constituted 'hiking.'

Reasoning: The court upheld that the decedent's actions could be classified as 'hiking,' thereby invoking the statute's protections.