Washington Law Review




A recent decision of the Washington Supreme Court casts considerable doubt on the exact status of the defense of assumption of risk, and illustrates a serious problem concerning the judicial process in Washington. The action was brought against a school district for injuries received by a spectator at a high school football game. The school district supervised the game, no admission was charged, and the plaintiff, as a relative of one of the football players, was encouraged to attend. The plaintiff, who had previously seen only one football game, was standing about one foot from the side lines when a player was knocked out of bounds and into her, permanently injuring her. The superior court concluded that defendant school district was not negligent, that the plaintiff was contributorily negligent, and that the plaintiff had voluntarily assumed the risk of being injured by standing in close proximity to the side lines. On appeal, the Washington Supreme Court affirmed. Held: Assumption of risk is one valid ground for denying a "social invitee" recovery for personal injuries. Perry v. Seattle School District, 66 Wash. Dec. 2d 786, 405 P.2d 589 (1965).

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