This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
The case involves a plaintiff who suffered severe injuries, including brain injury, during a horseback riding expedition at a recreational lodge. The plaintiff, a novice rider, signed an exculpatory agreement releasing the lodge from liability for negligence. During the ride, the plaintiff fell from the horse, allegedly due to improper saddling or faulty equipment, resulting in significant medical expenses and lost income (paras 2-7).
Procedural History
- District Court, Santa Fe County: Granted summary judgment in favor of the defendants, holding that the exculpatory agreement was enforceable and that the Equine Liability Act did not bar the defendants' immunity (paras 8-10).
Parties' Submissions
- Plaintiff-Appellant: Argued that the Equine Liability Act does not bar liability for injuries caused by faulty tack and that enforcing the exculpatory agreement violates public policy (para 8).
- Defendants-Appellees: Contended that the exculpatory agreement exculpated them from liability and that the Equine Liability Act shielded them from liability for injuries resulting from equine activities (para 8).
Legal Issues
- Whether the exculpatory agreement releasing the defendants from liability for negligence is enforceable.
- Whether the Equine Liability Act bars the plaintiff's claim for injuries caused by allegedly faulty tack or improper saddling.
Disposition
- The Court of Appeals reversed the district court's summary judgment in favor of the defendants and remanded the case for trial (para 31).
Reasons
Per A. Joseph Alarid J. (Celia Foy Castillo J. concurring):
The court held that exculpatory agreements relieving commercial operators of recreational facilities from liability for negligence are unenforceable as they violate public policy. The court reasoned that such agreements undermine the societal interests served by tort law, including deterring unreasonable conduct and redistributing the economic burden of loss. The court emphasized that operators of recreational facilities owe a non-disclaimable duty of care to patrons to protect them from foreseeable risks of serious physical injury or death (paras 1, 11-22).
Regarding the Equine Liability Act, the court interpreted the statute to allow liability for injuries caused by faulty tack or equipment, including improperly applied or positioned equipment. The court found sufficient evidence to create genuine issues of material fact as to whether the plaintiff's injuries were caused by improper saddling and whether the defendants knew or should have known of the faulty condition of the tack. Thus, the case was remanded for trial (paras 23-28).
Per Jonathan B. Sutin J., dissenting:
Judge Sutin dissented, arguing that the majority's decision to invalidate all exculpatory agreements in the recreational industry was overly broad and unwarranted. He emphasized the importance of freedom of contract and the long-standing enforceability of such agreements, subject to exceptions for public policy violations. He criticized the majority for departing from established law without sufficient justification and suggested that the issue of exculpatory agreements should be addressed by the legislature rather than the courts. He would have upheld the district court's decision enforcing the release and granting summary judgment to the defendants (paras 33-71).