Wagner v. Thomas J. Obert Enterprises

HUSPENI, Judge

(dissenting).

I respectfully dissent and would affirm the jury verdict and the trial court eviden-tiary rulings.

Primary Assumption of Risk

I believe a jury instruction on primary assumption of risk was appropriate under the facts of this case.

The doctrine of primary assumption of risk is a viable one, and in many cases is a matter for the trial court to resolve. See, e.g., Swagger v. City of Crystal, 379 N.W.2d 183 (Minn.Ct.App.1985), pet. for rev. denied, (Minn. Feb. 19, 1986) (this court affirmed the trial court’s judgment notwithstanding the verdict against the plaintiff on the basis of primary assumption of risk). The Minnesota Supreme Court recognizes, however, that a jury instruction on primary assumption of risk is appropriate in certain cases. See, e.g., Griffiths v. Lovelette Transfer Co., 313 N.W.2d 602, 605 (Minn.1981); Murphy v. City of Minneapolis, 292 N.W.2d 751, 755 n. 2 (Minn.1980).

Patrons of inherently dangerous sporting events are generally subject to the doctrine of primary assumption of risk. Springrose v. Willmore, 292 Minn. 23, 24, 192 N.W.2d 826, 827 (1971). Courts have consistently applied the doctrine of primary assumption of risk to patrons of skating rinks. See Moe v. Steenberg, 275 Minn. 448, 450-51, 147 N.W.2d 587, 589 (1966) (quoting Schamel v. St. Louis Arena Corp., 324 S.W.2d 375, 378 (Mo.Ct.App.1959)). Many courts consider that some bumping or jostling is an ordinary risk of roller-skating. See, e.g., Hills v. Skate Country East, Inc., 430 So.2d 1035 (La.Ct.App.), writ denied, 438 So.2d 568 (La.1983) (roller skater assumed risk of being bumped); Farinelli v. Laventure, 342 Mass. 157, 172 N.E.2d 825 (1961) (jury could determine based on evidence that ten-year-old roller skater did not assume risk of being hit by skaters who were violating rink rules by skating in a line when the rink operator recognized his obligation to deter such lines); Stemmler v. State, 32 A.D.2d 861, 861, 301 N.Y.S.2d 403, 404 (App.Div.1969) (the risk “[t]hat another participant in roller skating might strike the injured claimant was inherent in using the rink”); Pieraccini v. Crenshaw, 204 Tenn. 327, 321 S.W.2d 546 (1959) (roller-skating rink operator is not responsible for injuries to a patron who falls as a result of being bumped by another patron, unless operator had notice of dangerous conduct of patron).

The present case is unusual because the cause of the accident was seriously disputed. There is evidence in the record to support a number of different causal theories. At trial, respondent’s main theory was that Wagner fell while she was trying to avoid a child, that this kind of a fall was a risk inherent in the activity of roller-skating, and that respondent had no duty to Wagner with regard to such an inherent risk. There is evidence in the record from which the jury could have concluded that the sole cause of the accident was Wagner’s attempt to avoid colliding with a child. If the jury reached this conclusion on the causation issue, it could have further concluded that falling to avoid a child is a well-known and inherent risk of rollerskating. Therefore, based upon well-recognized principles of law, the doctrine of primary assumption of risk was applicable *486and respondent was entitled to a specific instruction on its theory of the case. See Sandhofer v. Abbott-Northwestern Hospital, 283 N.W.2d 362, 367 (Minn.1979).

I agree with the majority that the jury could have found that there was inadequate crowd control at the rink exit and, as a result of the overcrowding, Wagner fell trying to avoid a child. Further, the jury could have found merit in Wagner’s alternative theories regarding the rink’s lighting and the metal plate. Obviously, if the jury determined that any of the three theories propounded by Wagner was in fact the cause of the accident, it would have found the primary assumption of risk doctrine inapplicable. In that event, other instructions in the jury charge, which are not the subject of this appeal, would have adequately informed the jury of the applicable law.

I believe Thompson v. Hill, 366 N.W.2d 628 (Minn.Ct.App.1985) is distinguishable from the present case. The activity involved in Thompson (driving an automobile on ice) is not the type to which the supreme court has determined the doctrine of primary assumption of risk applies. See Springrose, 292 Minn. at 24, 192 N.W.2d at 827; Moe, 275 Minn. at 450, 147 N.W.2d at 589.

I do not share the majority’s concern that the trial court’s instructions confused the jury. In Kohoutek v. Hafner, 383 N.W.2d 295 (Minn.1986), the Minnesota Supreme Court recognized that trial courts have considerable latitude in formulating jury instructions and refused to grant a new trial on the basis of jury confusion. The supreme court noted that “[i]t is unnecessary that every possible opportunity for misapprehension be guarded against. If the charge fairly lays down the law of the case, it is sufficient.” Id. at 300 (quoting Cameron v. Evans, 241 Minn. 200, 209, 62 N.W.2d 793, 799 (1954)).

I do not believe that the jury here was confused. The instructions correctly set forth the doctrine of primary assumption of risk. The jury was required to determine whether the accident arose from a risk that was inherent and well-known to a rollerskating participant or from respondent’s negligence as alleged by Wagner. If the jury determined that the accident did arise from a risk inherent in the activity of roller-skating, it was instructed to answer the special interrogatory regarding respondent’s negligence in the negative. If it determined that respondent was negligent with respect to crowd control, lighting, or the condition of the metal plate, the jury was adequately instructed on the doctrine of comparative negligence.

Evidentiary Rulings

I find no abuse of discretion in the trial court’s rulings admitting into evidence the accident report, the doctor’s notes1 and the skating rink signs.

Pursuant to Minn.R.Evid. 801(d)(2)(A), Wagner’s statement that she tried to avoid a child at one of the exits and slipped is admissible as an admission of a party opponent. A record of the admission should also be admissible, assuming that a proper foundation is laid.

I agree with the majority that the doctor’s notes here are not admissible under the business records hearsay exception. Entries in medical records regarding the manner in which an accident occurred usually serve no medical purpose, and therefore are inadmissible under the business records hearsay exception. Lindstrom v. Yellow Taxi Co. of Minneapolis, 298 Minn. 224, 233-34, 214 N.W.2d 672, 678-79 (1974). However, if an entry comes within one of the other exceptions to the hearsay rule or does not even constitute hearsay in the first instance, it is admissible. McCormick on Evidence § 313, at 883 (3d ed. 1984). I believe that here the doctor’s notes regarding Wagner’s statement that she “was concerned about a child on the track when she lost her balance and fell” is an admission which is admissible under Rule 801(d)(2)(A). The doctor could properly testify to the fact that Wagner made the admission, and therefore a record *487of the admission should also be admissible assuming that a proper foundation is laid.

Neither Brown v. Saint Paul City Railway Co., 241 Minn. 15, 62 N.W.2d 688 (1954) nor Lindstrom prohibits the admission of the doctor’s notes as an admission of a party opponent. In Brown, the supreme court held that hearsay and self-serving statements contained in hospital records are not admissible to prove how an injury occurred, at least not when they are offered by the patient. Brown, 241 Minn. at 26, 62 N.W.2d at 696. The supreme court further stated:

Whether they are admissible for impeachment purposes or for some other purpose not here involved we need not now determine.

Id. at 26-27, 62 N.W.2d at 696. Brown only addressed the applicability of the business records hearsay exception to medical records that were not admissible under another hearsay exception. In Brown, unlike in the present case, the injured plaintiff offered the medical records into evidence to support her case. The statements in Brown were not admissions of a party opponent. In Lindstrom, the defendant sought to introduce hospital records concerning the cause of the accident under the business records hearsay exception when the treating physicians who made the entries were unavailable. 298 Minn. at 232, 214 N.W.2d at 678. There were no other applicable hearsay exceptions in Lindstrom.

I cannot agree with the majority’s narrow interpretation of Minn.R.Civ.P. 35.03. Rule 35.03 specifically states that a party who voluntarily places his physical condition in controversy “thereby waives any privilege he may have” regarding the testimony of anyone who has examined him “in respect of the same * * * physical * * * condition.” (Emphasis added).

Finally, I cannot conclude that the trial court abused its discretion in allowing the skating rink signs into evidence pursuant to Minn.R.Evid. 401. The signs were relevant to both Wagner’s knowledge of the risks involved in roller-skating and to whether Wagner’s accident arose from an inherent risk of roller-skating. I do not believe the signs misled the jury about the applicable standards of law. It does not appear that the trial court clearly abused its discretion in weighing the probative value of the signs against the risk of unduly prejudicing the jury. See Minn.R.Evid. 403; Jenson v. Touche Ross & Co., 335 N.W.2d 720, 725 (Minn.1983).

Damages Issue

The majority does not reach the damages issue raised by appellants, because it grants a new trial on other grounds. Because I find no reversible error in the jury instructions or the evidentiary rulings, I address the damages issue. The Wagners argue that the jury’s award of no damages indicates that the jury was influenced by prejudice and passion and warrants a new trial. If a jury determines that there are no grounds for liability, and there is evidence to support this finding, the failure of the jury to properly assess damages does not necessarily show prejudice or render the verdict perverse. Wefel v. Norman, 296 Minn. 506, 507-08, 207 N.W.2d 340, 341 (1973). Here, there is evidence to support the jury’s finding of no liability. I believe the trial court properly denied the Wag-ners’ motion for a new trial based on a perverse verdict.

. I note that Judge Wozniak joins the three dissenters on this issue.