assumption of risk defense (Arizona) · Go Syfert
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assumption of risk defense in Arizona

14 Arizona opinions name it 2 courts 1966–2013 0 in the last five years

The cases below were cited by Arizona courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (8)

CaseFollowedCited
Hildebrand v. Minyardgreen
arizctapp · 1972 · cited in 2 Arizona opinions naming this issue, 1972–2009
2 sentences

2009Id. ¶ 80 The District fails to identify how or when it presented evidence justifying an assumption of risk instruction under the Hildebrand test.

1972See Hildebrand v. Minyard, 16 Ariz.App. 583 , 494 P.2d 1328 (filed March 23, 1972).

12
Espinoza v. Schulenburggreen
ariz · 2006 · cited in 1 Arizona opinions naming this issue, 2013–2013
2 sentences

2013In Espinoza , our supreme court explained, however, that the assumption of risk doctrine does not provide an appropriate basis for application of the firefighter’s rule. 212 Ariz. at 218, ¶¶ 13-14 , 129 P.3d at 940 .

2013In Espinoza , our supreme court explained, however, that the assumption of risk doctrine does not provide an appropriate basis for application of the firefighter’s rule. 212 Ariz. at 218, ¶¶ 13-14 , 129 P.3d at 940 .

11
Salt River Project Agricultural Improvement & Power District v. Westinghouse Electric Corp.green
ariz · 1984 · cited in 1 Arizona opinions naming this issue, 2008–2008
2 sentences

2008See ... [SRP v. Westinghouse, 143 Ariz. at 384 , 694 P.2d at 214 ] (suggesting that summary judgment was inappropriate because there was a genuine fact question concerning whether the limitation of liability was actually bargained for).

2008See ... [SRP v. Westinghouse, 143 Ariz. at 384 , 694 P.2d at 214 ] (suggesting that summary judgment was inappropriate because there was a genuine fact question concerning whether the limitation of liability was actually bargained for).

11
Sirek v. Fairfield Snowbowl, Inc.green
arizctapp · 1990 · cited in 1 Arizona opinions naming this issue, 2005–2005
2 sentences

2005See Maurer v. Cerkvenik-Anderson Travel, Inc., 181 Ariz. 294, 298 , 890 P.2d 69, 73 (App.1994); Sirek v. Fairfield Snowbowl, Inc., 166 Ariz. 183, 185 , 800 P.2d 1291, 1293 (App.1990); see also Salt River Project Agric.

2005See Maurer v. Cerkvenik-Anderson Travel, Inc., 181 Ariz. 294, 298 , 890 P.2d 69, 73 (App.1994); Sirek v. Fairfield Snowbowl, Inc., 166 Ariz. 183, 185 , 800 P.2d 1291, 1293 (App.1990); see also Salt River Project Agric.

11
Maurer v. Cerkvenik-Anderson Travel, Inc.green
arizctapp · 1994 · cited in 1 Arizona opinions naming this issue, 2005–2005
2 sentences

2005See Maurer v. Cerkvenik-Anderson Travel, Inc., 181 Ariz. 294, 298 , 890 P.2d 69, 73 (App.1994); Sirek v. Fairfield Snowbowl, Inc., 166 Ariz. 183, 185 , 800 P.2d 1291, 1293 (App.1990); see also Salt River Project Agric.

2005See Maurer v. Cerkvenik-Anderson Travel, Inc., 181 Ariz. 294, 298 , 890 P.2d 69, 73 (App.1994); Sirek v. Fairfield Snowbowl, Inc., 166 Ariz. 183, 185 , 800 P.2d 1291, 1293 (App.1990); see also Salt River Project Agric.

11
City of Tucson v. Hollidaygreen
arizctapp · 1966 · cited in 1 Arizona opinions naming this issue, 1966–1966
1 sentence

1966See The City of Tucson v. Holliday, Ariz.App., 411 P.2d 183 , filed February 17, 1966.

11
Miller v. George F. Cook Construction Co.green
ariz · 1962 · cited in 1 Arizona opinions naming this issue, 1966–1966
2 sentences

1966It would seem, however, that such imposition of the doctrine by judicial fiat is proscribed in this state by the Arizona Constitution, art. 18, § 5, A.R.S.: “The defense of contributory negligence or of assumption of risk shall, in all cases whatsoever, be a question of fact and shall, at all times, be left to the jury.” In Miller v. George F. Cook Construction Co., 91 Ariz. 80 , 370 P.2d 53 (1962), our Supreme Court embraced the assumption of risk doctrine as a separate defense.

1966It would seem, however, that such imposition of the doctrine by judicial fiat is proscribed in this state by the Arizona Constitution, art. 18, § 5, A.R.S.: “The defense of contributory negligence or of assumption of risk shall, in all cases whatsoever, be a question of fact and shall, at all times, be left to the jury.” In Miller v. George F. Cook Construction Co., 91 Ariz. 80 , 370 P.2d 53 (1962), our Supreme Court embraced the assumption of risk doctrine as a separate defense.

11
Terry v. BOSS HOSTEL, INC.green
mo · 1964 · cited in 1 Arizona opinions naming this issue, 1966–1966
1 sentence

1966A case upholding the instruction, but indicating that the trial court should be allowed some discretion in this area, is Terry v. Boss Hotels, Inc., 376 S.W.2d 239, 248 (Mo. 1964).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Arizona. Read the followed side critically anyway.

Also cited on this issue (10)

CaseCitedYears
Phelps v. Firebird Raceway, Inc. green
ariz · 2005
2 sentences

2010We subsequently abrogated Salt River to the extent it suggested that courts may grant summary judgment to a defendant who asserts an assumption of risk defense, see Phelps v. Firebird Raceway, Inc., 210 Ariz. 403 , 410-11 n. 5, 111 P.3d 1003 , 1010-11 n. 5 (2005), an issue unrelated to the economic loss doctrine. 2 .

2010We subsequently abrogated Salt River to the extent it suggested that courts may grant summary judgment to a defendant who asserts an assumption of risk defense, see Phelps v. Firebird Raceway, Inc., 210 Ariz. 403 , 410-11 n. 5, 111 P.3d 1003 , 1010-11 n. 5 (2005), an issue unrelated to the economic loss doctrine. 2 .

22008–2010
McGriff v. McGriff green
ariz · 1977
2 sentences

1979The evidence viewed in the light most favorable to the giving of the assumption of risk instruction, McGriff v. McGriff, 114 Ariz. 323 , 560 P.2d 1230 (1977), establishes that plaintiff, then 19, and defendant Jerry Barney, 15, were deer hunting when Jerry slipped and fell, his rifle discharged, and plaintiff was shot in both ankles.

1979The evidence viewed in the light most favorable to the giving of the assumption of risk instruction, McGriff v. McGriff, 114 Ariz. 323 , 560 P.2d 1230 (1977), establishes that plaintiff, then 19, and defendant Jerry Barney, 15, were deer hunting when Jerry slipped and fell, his rifle discharged, and plaintiff was shot in both ankles.

11979–1979
Evans v. Pickett green
ariz · 1967
2 sentences

1977Viewing the facts in the light most favorable to the giving of the assumption of risk instruction, Evans v. Pickett, 102 Ariz. 393 , 430 P.2d 413 (1967), the following can be said to have occurred.

1977Viewing the facts in the light most favorable to the giving of the assumption of risk instruction, Evans v. Pickett, 102 Ariz. 393 , 430 P.2d 413 (1967), the following can be said to have occurred.

11977–1977
Tucson Utility Supplies, Inc. v. Gallagher neutral
ariz · 1967
2 sentences

1976Tucson Utility Supplies, Inc v. Gallagher, 102 Ariz. 499 , 433 P.2d 629 (1967).

1976Tucson Utility Supplies, Inc v. Gallagher, 102 Ariz. 499 , 433 P.2d 629 (1967).

11976–1976
Nichols v. Baker green
ariz · 1966
2 sentences

1975See Arizona Constitution, Article 18, Section 5, A.R.S.; Nichols v. Baker, 101 Ariz. 151 , 416 P.2d 584 (1966).

1975See Arizona Constitution, Article 18, Section 5, A.R.S.; Nichols v. Baker, 101 Ariz. 151 , 416 P.2d 584 (1966).

11975–1975
Rogers v. Los Angeles Transit Lines green
cal · 1955
2 sentences

1972Vierra v. Fifth Avenue Rental Service, supra; Rogers v. Los Angeles Transit Lines, 45 Cal.2d 414 , 289 P.2d 226 (1955) ; Hidden v. Malinoff, 174 Cal.App.2d 845 , 345 P.2d 409 (1959).

1972Vierra v. Fifth Avenue Rental Service, supra; Rogers v. Los Angeles Transit Lines, 45 Cal.2d 414 , 289 P.2d 226 (1955) ; Hidden v. Malinoff, 174 Cal.App.2d 845 , 345 P.2d 409 (1959).

11972–1972
Prescott v. Ralphs Grocery Co. green
cal · 1954
2 sentences

1972Although one may assume the risk of the negligence of another if he is fully informed of such negligence, Prescott v. Ralph’s Grocery Co., 42 Cal.2d 158 , 265 P.2d 904 (1954), one is not, under the doctrine of assumption of risk, bound to anticipate the negligent conduct of others.

1972Although one may assume the risk of the negligence of another if he is fully informed of such negligence, Prescott v. Ralph’s Grocery Co., 42 Cal.2d 158 , 265 P.2d 904 (1954), one is not, under the doctrine of assumption of risk, bound to anticipate the negligent conduct of others.

11972–1972
Hidden v. Malinoff green
calctapp · 1959
1 sentence

1972Vierra v. Fifth Avenue Rental Service, supra; Rogers v. Los Angeles Transit Lines, 45 Cal.2d 414 , 289 P.2d 226 (1955) ; Hidden v. Malinoff, 174 Cal.App.2d 845 , 345 P.2d 409 (1959).

11972–1972
Buffalo Shook Company v. Barksdale green
va · 1965
2 sentences

1966A case relatively in point, recognizing the assumption of risk defense, but holding that there was insufficient evidence in the particular case to show that the defendant appreciated and accepted the risk in question, is Buffalo Shook Company v. Barksdale, 206 Va. 45 , 141 S.E.2d 738 (1965).

1966A case relatively in point, recognizing the assumption of risk defense, but holding that there was insufficient evidence in the particular case to show that the defendant appreciated and accepted the risk in question, is Buffalo Shook Company v. Barksdale, 206 Va. 45 , 141 S.E.2d 738 (1965).

11966–1966
Halepeska v. Callihan Interests, Inc. red
tex · 1963
1 sentence

1966Justice Greenhill in Halepeska v. Callihan Interests, Inc., Tex, 371 S.W.2d 368, 378 , indicates in note 3 to his opinion that the American Law Institute Council unanimously accepted the recommendation that assumption of risk remain in the Restatement, despite the opposition of “The Confederacy,” consisting of Deans Page, Keeton and Wade, Professors James, Malone, Morris, Seavey and Thurman.

11966–1966

Statutes the citing opinions construe

AZ § Ariz. Rev. Stat. § 12-120.24 (3) AZ § Ariz. Rev. Stat. § 32-1159 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NY 313 (1927–2026) CA 206 (1909–2025) IL 55 (1909–2023) PA 45 (1910–2024) OH 42 (1941–2025) GA 39 (1934–2025) MD 34 (1963–2017) MI 29 (1910–2021) MS 29 (1955–2018) MN 28 (1952–2019) WA 26 (1948–2025) IA 24 (1903–2022) KS 23 (1915–2026) LA 21 (1937–2004) MO 20 (1904–1995) VA 17 (1916–2017) CT 16 (1942–2020) TX 15 (1972–2025) AZ 14 (1966–2013) IN 13 (1901–2011) NC 13 (1902–2025) FL 13 (1915–2013) UT 11 (1916–2021) OR 9 (1908–1984) NE 9 (1984–2020) CO 9 (1959–2020) WV 9 (1972–2001) DC 9 (1980–2013) ID 8 (1968–2025) SC 8 (1965–2025) HI 8 (1965–2023) NM 7 (1961–1996) MT 7 (1906–2016) AL 6 (1951–1994) NJ 6 (1911–2026) MA 6 (1907–2015) VT 6 (1912–1994) OK 6 (1913–1997) DE 6 (1978–2022) ND 6 (1923–1990) WY 6 (1967–2012) RI 6 (1980–2014) SD 5 (1935–2008) WI 4 (1949–2024) TN 4 (1928–1998) AR 4 (1932–2019) KY 4 (1952–2005) AK 4 (1968–1991) NH 2 (1924–2010) NV 2 (2017–2017)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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