assumption of the risk doctrine (Minnesota) · Go Syfert
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assumption of the risk doctrine in Minnesota

14 Minnesota opinions name it 2 courts 1979–2016 0 in the last five years

The cases below were cited by Minnesota 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 (14)

CaseFollowedCited
Armstrong v. Mailandgreen
minn · 1979 · cited in 2 Minnesota opinions naming this issue, 1991–2002
2 sentences

2002In Spring-rose, the Minnesota Supreme Court reaffirmed the existence of primary assumption of the risk as a valid principle in Minnesota, and an absolute bar to a plain *149 tiffs recovery. 2 292 Minn. at 24 , 192 N.W.2d at 827 ; see also Mailand, 284 N.W.2d at 348-49 (stating that in Spring-rose, the supreme court held that “primary assumption of the risk remains as an absolute bar to the plaintiffs recovery”).

1991See Armstrong, 284 N.W.2d at 352 .

22
Adee v. Evansongreen
minn · 1979 · cited in 2 Minnesota opinions naming this issue, 1984–1986
2 sentences

1986See Adee v. Evanson, 281 N.W.2d 177, 180 (Minn.1979) (where court upheld the instruction on assumption of the risk because the presence of an alternative safe route was clear).

1984See Adee v. Evanson, 281 N.W.2d 177, 180 (Minn.1979) (where court upheld the instruction on assumption of the risk *600 because the presence of an alternative safe route was clear).

22
Goodwin v. Legionville School Safety Patrol Training Center, Inc.green
minnctapp · 1988 · cited in 1 Minnesota opinions naming this issue, 2015–2015
1 sentence

2015See Goodwin v. Legionville School Safety Patrol Training Center, 422 N.W.2d 46, 50 (Minn. App. 1988) (applying primary assumption of risk doctrine to bar claims for injuries that arose out of a fall from a roof as a matter of law where falling off a roof was a well-known, obvious, and incidental risk to the activity of roofing, and where plaintiff, who had experience in shingling roofs and who was familiar with safety precautions which could be used while roofing, went up on a roof voluntarily, knowing that all roofs were hazardous and fell), review denied (Minn. June 23, 1988).

11
Peterson Ex Rel. Peterson v. Donahuegreen
minnctapp · 2007 · cited in 1 Minnesota opinions naming this issue, 2013–2013
1 sentence

2013See, e.g., Peterson, 733 N.W.2d at 790-91 (risk assumed by experienced 11-year-old who was in his fourth year on a ski race team). .

11
Bjerke v. Johnsongreen
minnctapp · 2007 · cited in 1 Minnesota opinions naming this issue, 2007–2007
2 sentences

2007Bjerke v. Johnson, 727 N.W.2d 183, 189-96 (Minn.App.2007).

2007Bjerke v. Johnson, 727 N.W.2d 183, 189-96 (Minn. App.2007).

11
Jussila v. United States Snowmobile Ass'ngreen
minnctapp · 1996 · cited in 1 Minnesota opinions naming this issue, 2003–2003
1 sentence

2003See, e.g., Grisim v. TapeMark Charity Pro-Am Golf Tournament, 415 N.W.2d 874 (Minn.1987) (holding that a golf tournament spectator assumes the risks inherent in being on a golf course and the only duty to the spectator is to provide a reasonably safe area to watch); Modec, 224 Minn. at 563-64 , 29 N.W.2d at 456-57 (holding that summary judgment was appropriate because a spectator who was hit by a hockey puck at a hockey game assumed the risks incident to the game); Jussila v. U.S. Snowmobile Ass’n, 556 N.W.2d 234, 237 (Minn.App.1996), review denied (Minn. Jan. 29, 1997) (holding that the doctr

11
Grisim v. TapeMark Charity Pro-Am Golf Tournamentgreen
minn · 1987 · cited in 1 Minnesota opinions naming this issue, 2003–2003
1 sentence

2003See, e.g., Grisim v. TapeMark Charity Pro-Am Golf Tournament, 415 N.W.2d 874 (Minn.1987) (holding that a golf tournament spectator assumes the risks inherent in being on a golf course and the only duty to the spectator is to provide a reasonably safe area to watch); Modec, 224 Minn. at 563-64 , 29 N.W.2d at 456-57 (holding that summary judgment was appropriate because a spectator who was hit by a hockey puck at a hockey game assumed the risks incident to the game); Jussila v. U.S. Snowmobile Ass’n, 556 N.W.2d 234, 237 (Minn.App.1996), review denied (Minn. Jan. 29, 1997) (holding that the doctr

11
Modec v. City of Evelethgreen
minn · 1947 · cited in 1 Minnesota opinions naming this issue, 2003–2003
2 sentences

2003See, e.g., Grisim v. TapeMark Charity Pro-Am Golf Tournament, 415 N.W.2d 874 (Minn.1987) (holding that a golf tournament spectator assumes the risks inherent in being on a golf course and the only duty to the spectator is to provide a reasonably safe area to watch); Modec, 224 Minn. at 563-64 , 29 N.W.2d at 456-57 (holding that summary judgment was appropriate because a spectator who was hit by a hockey puck at a hockey game assumed the risks incident to the game); Jussila v. U.S. Snowmobile Ass’n, 556 N.W.2d 234, 237 (Minn.App.1996), review denied (Minn. Jan. 29, 1997) (holding that the doctr

2003See, e.g., Grisim v. TapeMark Charity Pro-Am Golf Tournament, 415 N.W.2d 874 (Minn.1987) (holding that a golf tournament spectator assumes the risks inherent in being on a golf course and the only duty to the spectator is to provide a reasonably safe area to watch); Modec, 224 Minn. at 563-64 , 29 N.W.2d at 456-57 (holding that summary judgment was appropriate because a spectator who was hit by a hockey puck at a hockey game assumed the risks incident to the game); Jussila v. U.S. Snowmobile Ass’n, 556 N.W.2d 234, 237 (Minn.App.1996), review denied (Minn. Jan. 29, 1997) (holding that the doctr

11
Tiller v. Atlantic Coast Line Railroadgreen
scotus · 1943 · cited in 1 Minnesota opinions naming this issue, 2002–2002
2 sentences

2002See Tiller v. Atlantic Coast Line R.R., 318 U.S. 54, 58-9 , 63 S.Ct. 444, 447 , 87 L.Ed. 610 (1943) (stating that assumption of risk first developed in the United States to protect employers); Geis v. Hodgman, 255 Minn. 1, 4-5 , 95 N.W.2d 311, 313-15 (1959) (applying assumption of risk in master/servant context).

2002See Tiller v. Atlantic Coast Line R.R., 318 U.S. 54, 58-9 , 63 S.Ct. 444, 447 , 87 L.Ed. 610 (1943) (stating that assumption of risk first developed in the United States to protect employers); Geis v. Hodgman, 255 Minn. 1, 4-5 , 95 N.W.2d 311, 313-15 (1959) (applying assumption of risk in master/servant context).

11
Arnold v. City of Cedar Rapidsgreen
iowa · 1989 · cited in 1 Minnesota opinions naming this issue, 2002–2002
1 sentence

2002See, e.g., Arnold v. City of Cedar Rapids, 443 N.W.2d 332, 333 (Iowa 1989) (stating that it is preferable to frame issues of primary assumption of the risk in terms of whether a duty is owed); Meistrich v. Casino Arena Attractions, Inc., 31 N.J. 44 , 155 A.2d 90, 97 (1959) (characterizing issues of primary assumption of the risk as negligence issues); Perez v. McConkey, 872 S.W.2d 897, 905 (Tenn.1994) (holding that the doctrine of primary assumption of the risk has no useful purpose, and adopting the common law concept of duty to analyze issues of primary assumption of risk). 3 .

11
Geis v. Hodgmangreen
minn · 1959 · cited in 1 Minnesota opinions naming this issue, 2002–2002
2 sentences

2002See Tiller v. Atlantic Coast Line R.R., 318 U.S. 54, 58-9 , 63 S.Ct. 444, 447 , 87 L.Ed. 610 (1943) (stating that assumption of risk first developed in the United States to protect employers); Geis v. Hodgman, 255 Minn. 1, 4-5 , 95 N.W.2d 311, 313-15 (1959) (applying assumption of risk in master/servant context).

2002See Tiller v. Atlantic Coast Line R.R., 318 U.S. 54, 58-9 , 63 S.Ct. 444, 447 , 87 L.Ed. 610 (1943) (stating that assumption of risk first developed in the United States to protect employers); Geis v. Hodgman, 255 Minn. 1, 4-5 , 95 N.W.2d 311, 313-15 (1959) (applying assumption of risk in master/servant context).

11
Perez v. McConkeygreen
tenn · 1994 · cited in 1 Minnesota opinions naming this issue, 2002–2002
1 sentence

2002See, e.g., Arnold v. City of Cedar Rapids, 443 N.W.2d 332, 333 (Iowa 1989) (stating that it is preferable to frame issues of primary assumption of the risk in terms of whether a duty is owed); Meistrich v. Casino Arena Attractions, Inc., 31 N.J. 44 , 155 A.2d 90, 97 (1959) (characterizing issues of primary assumption of the risk as negligence issues); Perez v. McConkey, 872 S.W.2d 897, 905 (Tenn.1994) (holding that the doctrine of primary assumption of the risk has no useful purpose, and adopting the common law concept of duty to analyze issues of primary assumption of risk). 3 .

11
Meistrich v. Casino Arena Attractions, Inc.green
nj · 1959 · cited in 1 Minnesota opinions naming this issue, 2002–2002
2 sentences

2002See, e.g., Arnold v. City of Cedar Rapids, 443 N.W.2d 332, 333 (Iowa 1989) (stating that it is preferable to frame issues of primary assumption of the risk in terms of whether a duty is owed); Meistrich v. Casino Arena Attractions, Inc., 31 N.J. 44 , 155 A.2d 90, 97 (1959) (characterizing issues of primary assumption of the risk as negligence issues); Perez v. McConkey, 872 S.W.2d 897, 905 (Tenn.1994) (holding that the doctrine of primary assumption of the risk has no useful purpose, and adopting the common law concept of duty to analyze issues of primary assumption of risk). 3 .

2002See, e.g., Arnold v. City of Cedar Rapids, 443 N.W.2d 332, 333 (Iowa 1989) (stating that it is preferable to frame issues of primary assumption of the risk in terms of whether a duty is owed); Meistrich v. Casino Arena Attractions, Inc., 31 N.J. 44 , 155 A.2d 90, 97 (1959) (characterizing issues of primary assumption of the risk as negligence issues); Perez v. McConkey, 872 S.W.2d 897, 905 (Tenn.1994) (holding that the doctrine of primary assumption of the risk has no useful purpose, and adopting the common law concept of duty to analyze issues of primary assumption of risk). 3 .

11
Kantorowicz v. VFW Post, No. 230green
minnctapp · 1984 · cited in 1 Minnesota opinions naming this issue, 1985–1985
1 sentence

1985Kantorowicz v. VFW Post, No. 230, 349 N.W.2d 597, 599 (Minn.Ct.App.1984).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (7)

CaseCitedYears
Springrose v. Willmore green
minn · 1971
2 sentences

1982In Springrose v. Willmore, 292 Minn. 23 , 192 N.W.2d 826 (1971), the scope of that statute was judicially expanded to include the assumption of the risk defense.

1982In Springrose v. Willmore, 292 Minn. 23 , 192 N.W.2d 826 (1971), the scope of that statute was judicially expanded to include the assumption of the risk defense.

31979–2002
Janke v. Duluth & Northeastern Railroad green
minnctapp · 1992
1 sentence

2016See 45 U.S.C. § 54 ; Janke, 489 N.W.2d at 547 .

12016–2016
Daly v. McFarland green
minn · 2012
1 sentence

2013Citing statistics and Daly, 812 N.W.2d at 120 , Crystal Valley argues that this Court should conclude that farming — and more specifically working with a tractor — carries far more inherent danger than any of the sports spectating events which have been identified by the Minnesota Supreme Court as being the types of cases most common for application of the doctrine of primary assumption of the risk.

12013–2013
Wagner v. Thomas J. Obert Enterprises green
minn · 1986
1 sentence

2003Id.

12003–2003
Andren v. White-Rodgers Co. green
minnctapp · 1991
1 sentence

1994While a jury could find that the plaintiff had secondarily assumed the risk of his injury, the Baber court held, “[t]he hazardous reinforcing rods were not so clearly a necessary and incidental risk of guiding the backhoe as to invoke the doctrine of primary assumption of the risk as a matter of law.” Id.

11994–1994
Busch v. Busch Construction, Inc. green
minn · 1977
2 sentences

1982The statute underwent a second redefinition in Busch v. Busch Construction, Inc., 262 N.W.2d 377 (Minn.1977), when it was applied to strict liability claims as well.

1982The statute underwent a second redefinition in Busch v. Busch Construction, Inc., 262 N.W.2d 377 (Minn.1977), when it was applied to strict liability claims as well.

11982–1982
Peterson v. Balach green
minn · 1972
2 sentences

1979In Peterson v. Balach, 294 Minn. 161 , 199 N.W.2d 639 (1972), this court held the status of licensee or invitee was no longer conclusive in determining a landowner’s duty to entrants.

1979In Peterson v. Balach, 294 Minn. 161 , 199 N.W.2d 639 (1972), this court held the status of licensee or invitee was no longer conclusive in determining a landowner’s duty to entrants.

11979–1979

Statutes the citing opinions construe

MN § Minn. Stat. § 604.01 (5)

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 161 (1953–2026) CA 83 (1935–2025) OH 66 (1972–2023) PA 62 (1978–2025) GA 58 (1976–2026) LA 24 (1961–2023) MD 21 (1971–2012) MN 14 (1979–2016) CT 12 (1991–2017) RI 11 (1958–2011) AL 11 (1990–2009) IL 10 (1974–2006) SC 9 (1986–2025) MS 9 (1989–2008) TN 8 (1933–2003) NJ 8 (1989–2021) MA 7 (1973–2009) OR 7 (1931–2022) DC 7 (2003–2017) TX 7 (1983–2019) VA 7 (1990–2026) MI 6 (1916–2021) SD 6 (1979–2018) FL 6 (1964–1995) WA 6 (1962–2016) ME 4 (1976–2016) MO 4 (1905–1995) NV 4 (2023–2024) KS 4 (1985–2017) NH 4 (1987–1999) AZ 3 (1976–2005) NM 3 (1992–2009) IA 3 (2010–2017) ID 3 (1976–2025) OK 2 (1993–1994) CO 2 (1983–2015) MT 2 (1983–2012) KY 2 (1984–2015) DE 2 (2024–2024)

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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