This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
During a senior Little League baseball practice, a teenage team member was fatally injured after falling from the back of a pickup truck while being transported between fields. The coach had directed the boys to ride inside the camper of the truck, but some, including the deceased, disobeyed and rode on the bumper instead. The driver, a minor, was unaware of their actions due to limited visibility (paras 2-7).
Procedural History
- District Court of Grant County: Granted summary judgment in favor of all defendants, dismissing the plaintiffs' wrongful death claims.
Parties' Submissions
- Plaintiffs-Appellants: Argued that the driver of the truck, his parents, the coach, and Little League were negligent in their actions or supervision, which led to the death of their son. They contended that the trial court erred in granting summary judgment and in refusing to consider late affidavits and oral testimony (paras 1, 8-9, 20).
- Defendants-Appellees (Gomez family): Asserted that the truck was not negligently entrusted to the minor driver, that the driver was not negligent, and that the injury was unforeseeable (para 3).
- Defendants-Appellees (Coach and Little League): Claimed that the coach exercised due care in supervising the players and that the accident was unforeseeable. They also argued that the plaintiffs failed to provide admissible evidence to rebut their motions for summary judgment (paras 3, 19-20).
Legal Issues
- Did the trial court err in granting summary judgment in favor of the defendants?
- Was the trial court correct in refusing to consider late affidavits and oral testimony submitted by the plaintiffs?
- Were the defendants negligent, and was the injury foreseeable?
Disposition
- The summary judgment in favor of the Gomez family was reversed.
- The summary judgment in favor of the coach and Little League was affirmed (paras 9, 33-34).
Reasons
Per Donnelly J. (Alarid C.J. and Bivins J. concurring):
Summary Judgment Standards: Summary judgment is appropriate only when there are no genuine issues of material fact, and the moving party is entitled to judgment as a matter of law. Negligence and foreseeability are generally questions of fact for the jury unless the facts are undisputed and only one reasonable inference can be drawn (paras 10-13).
Gomez Family: The court found that genuine issues of material fact existed regarding whether the minor driver acted negligently and whether his parents, as vehicle owners, were liable under the family purpose doctrine. The evidence suggested that the driver may have known or should have known that the boys were riding on the bumper, raising questions for the fact-finder (paras 14-16).
Coach: The coach had explicitly instructed the boys to ride inside the camper and had no prior reason to believe they would disobey. The court held that the accident was not reasonably foreseeable, and the coach had exercised reasonable care under the circumstances. Thus, summary judgment in his favor was proper (paras 17-19, 28-31).
Little League: Since the plaintiffs' claims against Little League were contingent on the coach's alleged negligence, and the court found no negligence on the coach's part, summary judgment in favor of Little League was also appropriate (para 32).
Late Evidence: The trial court erred in refusing to consider the late affidavits submitted by the plaintiffs, as there was no showing of prejudice to the defendants. However, these affidavits did not affect the rulings in favor of the coach and Little League but supported the reversal of summary judgment for the Gomez family (paras 20-27).