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Gifford v. Vail Resorts, Inc.

Citation: 37 F. App'x 486Docket: Nos. 01-1155, 01-1191

Court: Court of Appeals for the Tenth Circuit; June 14, 2002; Federal Appellate Court

Narrative Opinion Summary

In this diversity case, the plaintiff, representing herself, appealed a jury verdict in favor of a ski resort operator regarding negligence claims stemming from the wrongful death of her son, who died skiing due to asphyxiation in a natural gully. The plaintiff argued the resort failed to adequately mark the gully and violated the Colorado Ski Safety Act for not posting a 'Danger' sign. The jury found the death resulted from inherent skiing risks, thus shielding the operator from liability under the Act. The plaintiff contested the jury instructions and the district court's handling of expert testimony and a liability waiver. Despite recognizing instructional errors, the appellate court held these were non-prejudicial and affirmed the lower court's decision, dismissing the operator's cross-appeal as moot. The court emphasized that inherent risks included natural terrain variations, which did not necessitate warning signs under the statute, and upheld the district court's evidentiary rulings. The ruling underscored the broad protection afforded to ski operators under the Ski Safety Act against liability for inherent skiing dangers.

Legal Issues Addressed

Admissibility of Liability Waiver

Application: The court found no abuse of discretion in admitting the season pass application, which included a liability waiver, as it was relevant to comparative fault issues.

Reasoning: The district court properly admitted the season pass application, instructing the jury that it should not consider the application as a waiver of claims.

Colorado Ski Safety Act Compliance

Application: The court examined whether the ski area operator had a duty to post a 'Danger' sign under the Ski Safety Act, ultimately finding no such obligation for natural features.

Reasoning: The statute does not classify inherent danger areas as such, further supported by case law indicating no obligation to post danger signs in these areas.

Expert Witness Testimony

Application: The court upheld the district court's decision to limit the use of the term 'expert' while allowing the witness to provide testimony based on expertise.

Reasoning: The court instructed the jury on the qualifications for expert testimony and allowed Mr. Penniman to testify based on his expertise, indicating that the jury was properly informed of his qualifications.

Jury Instructions and Prejudicial Error

Application: The court determined that any instructional errors regarding inherent dangers and statutory violations were not prejudicial to the outcome of the case.

Reasoning: Although acknowledging this as an error, the court concluded that it was not prejudicial.

Negligence and Inherent Risks in Skiing

Application: The court found that the decedent's death was due to the inherent risks of skiing and not due to negligence by the ski resort operator.

Reasoning: The jury concluded that Mr. Gifford's death resulted from inherent dangers of skiing, leading to a judgment in favor of Vail under the Ski Safety Act, which shields operators from liability for such risks.