Organizer of Sports Tournament Who Required Attendees To Stay At a Hotel Dismissed as a Defendant in Premises Liability Case

In this matter, the Plaintiff sued the owner of the hotel where the accident happened along with a Defendant entity that ran ice hockey tournaments and who required the participants in the tournament to stay at the hotel.

The entity that ran the ice hockey tournaments filed a Motion for Judgment on the Pleadings seeking to be dismissed on the grounds that it had no duty to maintain the premises where the accident happened.   

In this matter, the district court reaffirmed the general rule of law that premises liability does not extend to parties who are not in control of the relevant premises. Rather, the premises liability is focused on the relationship between the individual or entity in control of the premises and the business invitee who ventured on the premises.

The court ruled that the Plaintiffs cannot impute a premises liability duty upon a third-party who is not affiliated with the property.

More specifically, the court ruled that the fact that the organizer of the tournament merely place a hotel on an approved list for the attendees of the tournament did not impose a duty on the organizer of the tournament to inspect that hotel. Furthermore, any such alleged duties were entirely duplicative of the duties already imposed upon the hotel operator itself.

The court offered the additional rationale in support of its Motion to Dismiss by asserting that extending duties to persons without control over the property has no social utility and would, instead, reduce the safety incentives for the actual property owner.

Anyone wishing to review a copy of this decision may click this LINK.

I send thanks to Attorney James M. Beck of the Reed Smith office in Philadelphia for bringing this case to my attention.