EQUINE ACTIVITY LIABILITY ACT
Act 351 of 1994
691.1662 Definitions.
Sec. 2.
As used in this act:
(a) "Engage in an equine activity" means riding, training, driving, breeding, being a passenger upon, or providing or assisting in veterinary treatment of an equine, whether mounted or unmounted. Engage in an equine activity includes visiting, touring, or utilizing an equine facility as part of an organized event or activity including the breeding of equines, or assisting a participant or show management. Engage in equine activity does not include spectating at an equine activity, unless the spectator places himself or herself in an unauthorized area and in immediate proximity to the equine activity.
(b) "Equine" means horse, pony, mule, donkey, or hinny.
(c) "Equine activity" means any of the following:
(i) An equine show, fair, competition, performance, or parade including, but not limited to, dressage, a hunter and jumper horse show, grand prix jumping, a 3-day event, combined training, a rodeo, riding, driving, pulling, cutting, polo, steeplechasing, English and western performance riding, endurance trail riding, gymkhana games, and hunting.
(ii) Equine training or teaching activities.
(iii) Boarding equines, including their normal daily care.
(iv) Breeding equines, including the normal daily care and activities associated with breeding equines.
(v) Riding, inspecting, or evaluating an equine belonging to another, whether or not the owner receives monetary consideration or another thing of value for the use of the equine or is permitting a prospective purchaser of the equine or an agent to ride, inspect, or evaluate the equine.
(vi) A ride, trip, hunt, or other activity, however informal or impromptu, that is sponsored by an equine activity sponsor.
(vii) Placing or replacing a horseshoe on or hoof trimming of an equine.
(d) "Equine activity sponsor" means an individual, group, club, partnership, or corporation, whether or not operating for profit, that sponsors, organizes, or provides the facilities for an equine activity, including, but not limited to, a pony club; 4-H club; hunt club; riding club; school- or college-sponsored class, program, or activity; therapeutic riding program; stable or farm owner; and operator, instructor, or promoter of an equine facility including, but not limited to, a stable, clubhouse, ponyride string, fair, or arena at which the equine activity is held.
(e) "Equine professional" means a person engaged in any of the following for compensation:
(i) Instructing a participant in an equine activity.
(ii) Renting an equine, equipment, or tack to a participant.
(iii) Providing daily care of horses boarded at an equine facility.
(iv) Training an equine.
(v) Breeding of equines for resale or stock replenishment.
(f) "Inherent risk of an equine activity" means a danger or condition that is an integral part of an equine activity, including, but not limited to, any of the following:
(i) An equine's propensity to behave in ways that may result in injury, harm, or death to a person on or around it.
(ii) The unpredictability of an equine's reaction to things such as sounds, sudden movement, and people, other animals, or unfamiliar objects.
(iii) A hazard such as a surface or subsurface condition.
(iv) Colliding with another equine or object.
(g) "Participant" means an individual, whether amateur or professional, engaged in an equine activity, whether or not a fee is paid to participate.
History: 1994, Act 351, Eff. Mar. 30, 1995
Notes of Decisions
Cited in
11
cases (
5 in the last 5 years), 2000–2025 · leading case:
Amburgey v. Sauder, 605 N.W.2d 84 (Mich. Ct. App. 2000).
Amburgey v. Sauder, 605 N.W.2d 84 (Mich. Ct. App. 2000).
· cites it 6× “[MCL 691.1662; MSA 12.418(2) (emphasis added).”
Beattie v. Mickalich, 773 N.W.2d 748 (Mich. Ct. App. 2009).
· cites it 13× “[MCL 691.1662(a) (emphasis added).] And, “equine activity” means, but is not limited to: (ii) Equine training or teaching activities.”
Cole v. Ladbroke Racing Michigan, Inc, 614 N.W.2d 169 (Mich. Ct. App. 2000).
“” *12 The legislative history shows that the purpose behind the eala was to protect commercial riding stables from claims for damages resulting from the inherent risks of horseback riding and being around horses.”
Beattie v. MICKALICH, 784 N.W.2d 38 (Mich. 2010).
· cites it 2× “NOTES [1] I concur with the majority's assessment that the Court of Appeals incorrectly shifted the burden onto plaintiff to state her claims in avoidance of the EALA limitation on liability.”
Gardner v. Simon, 445 F. Supp. 2d 786 (W.D. Mich. 2006).
· cites it 4× “Mich. Comp. Laws § 691.1662 (f). As the Michigan Court of Appeals has held, the definition of “inherent risk” encompasses more than simply “normal and anticipated equine behavior.”
Violet Lapeer v. Otsego Cnty. Fair Ass'n (Mich. Ct. App. 2021).
· cites it 7× “[MCL 691.1662(a) (emphasis added).] To summarize, the EALA precludes a participant in an equine activity from asserting a claim against an equine activity sponsor for injuries arising from an inherent risk of an equine activity.”
Jeff Britten v. Circle H Stables Inc (Mich. Ct. App. 2023).
· cites it 3× “1662(d), and plaintiff was injured when “engage[d] in an equine activity” within the meaning of MCL 691.1662(a). The EALA provides five enumerated exclusions from its general grant of immunity: [MCL 691.”
Rebecca Goch v. the Edison Inst. (Mich. Ct. App. 2025).
· cites it 3× “The act of “driving” is recognized as a form of participation in an equine activity (MCL 691.1662(a)). The term “drive” is typically defined to encompass directing the movement and course of a draft animal, operating a vehicle, or being transported in a vehicle, as per…”
Samantha Johnson v. Outback Lodge & Equestrian Ctr. LLC (Mich. Ct. App. 2016).
· cites it 2× “” MCL 691.1662(c)(v). The § 5 exceptions to § 3’s limitation on liability apply if the equine activity sponsor or professional has done any of the following: (a) Provides equipment or tack and knows or should know that the equipment or tack is faulty, and the equipment or tack…”
Violet Lapeer v. Otsego Cnty. Fair Ass'n (Mich. Ct. App. 2021).
· cites it 2× “Engage in an equine activity includes visiting, touring, or utilizing an equine facility as part of an organized event or activity including the breeding of equines, or assisting a participant or show management. Engage in equine activity does not include spectating at an equine…”
— Mich. Comp. Laws § 691.1662(A) — 1 case
Violet Lapeer v. Otsego Cnty. Fair Ass'n (Mich. Ct. App. 2021).
“Engage in an equine activity includes visiting, touring, or utilizing an equine facility as part of an organized event or activity including the breeding of equines, or assisting a participant or show management. Engage in equine activity does not include spectating at an equine…”
— Mich. Comp. Laws § 691.1662(a) — 4 cases
Beattie v. Mickalich, 773 N.W.2d 748 (Mich. Ct. App. 2009).
“[MCL 691.1662(a) (emphasis added).] And, “equine activity” means, but is not limited to: (ii) Equine training or teaching activities.”
Violet Lapeer v. Otsego Cnty. Fair Ass'n (Mich. Ct. App. 2021).
“[MCL 691.1662(a) (emphasis added).] To summarize, the EALA precludes a participant in an equine activity from asserting a claim against an equine activity sponsor for injuries arising from an inherent risk of an equine activity.”
Rebecca Goch v. the Edison Inst. (Mich. Ct. App. 2025).
“The act of “driving” is recognized as a form of participation in an equine activity (MCL 691.1662(a)). The term “drive” is typically defined to encompass directing the movement and course of a draft animal, operating a vehicle, or being transported in a vehicle, as per…”
Jeff Britten v. Circle H Stables Inc (Mich. Ct. App. 2023).
“1662(d), and plaintiff was injured when “engage[d] in an equine activity” within the meaning of MCL 691.1662(a). The EALA provides five enumerated exclusions from its general grant of immunity: [MCL 691.”
— Mich. Comp. Laws § 691.1662(c) — 2 cases
Beattie v. Mickalich, 773 N.W.2d 748 (Mich. Ct. App. 2009).
“[MCL 691.1662(a) (emphasis added).] And, “equine activity” means, but is not limited to: (ii) Equine training or teaching activities.”
Violet Lapeer v. Otsego Cnty. Fair Ass'n (Mich. Ct. App. 2021).
“[MCL 691.1662(a) (emphasis added).] To summarize, the EALA precludes a participant in an equine activity from asserting a claim against an equine activity sponsor for injuries arising from an inherent risk of an equine activity.”
— Mich. Comp. Laws § 691.1662(c)(ii) — 1 case
— Mich. Comp. Laws § 691.1662(c)(v) — 1 case
Samantha Johnson v. Outback Lodge & Equestrian Ctr. LLC (Mich. Ct. App. 2016).
“” MCL 691.1662(c)(v). The § 5 exceptions to § 3’s limitation on liability apply if the equine activity sponsor or professional has done any of the following: (a) Provides equipment or tack and knows or should know that the equipment or tack is faulty, and the equipment or tack…”
— Mich. Comp. Laws § 691.1662(d) — 4 cases
Jeff Britten v. Circle H Stables Inc (Mich. Ct. App. 2023).
“1662(d), and plaintiff was injured when “engage[d] in an equine activity” within the meaning of MCL 691.1662(a). The EALA provides five enumerated exclusions from its general grant of immunity: [MCL 691.”
Samantha Johnson v. Outback Lodge & Equestrian Ctr. LLC (Mich. Ct. App. 2016).
“” MCL 691.1662(c)(v). The § 5 exceptions to § 3’s limitation on liability apply if the equine activity sponsor or professional has done any of the following: (a) Provides equipment or tack and knows or should know that the equipment or tack is faulty, and the equipment or tack…”
Violet Lapeer v. Otsego Cnty. Fair Ass'n (Mich. Ct. App. 2021).
“[MCL 691.1662(a) (emphasis added).] To summarize, the EALA precludes a participant in an equine activity from asserting a claim against an equine activity sponsor for injuries arising from an inherent risk of an equine activity.”
— Mich. Comp. Laws § 691.1662(e) — 2 cases
Amburgey v. Sauder, 605 N.W.2d 84 (Mich. Ct. App. 2000).
“[MCL 691.1662; MSA 12.418(2) (emphasis added).”
Beattie v. Mickalich, 773 N.W.2d 748 (Mich. Ct. App. 2009).
“[MCL 691.1662(a) (emphasis added).] And, “equine activity” means, but is not limited to: (ii) Equine training or teaching activities.”
— Mich. Comp. Laws § 691.1662(e)(i) — 1 case
— Mich. Comp. Laws § 691.1662(f) — 3 cases
Beattie v. Mickalich, 773 N.W.2d 748 (Mich. Ct. App. 2009).
“[MCL 691.1662(a) (emphasis added).] And, “equine activity” means, but is not limited to: (ii) Equine training or teaching activities.”
Beattie v. MICKALICH, 784 N.W.2d 38 (Mich. 2010).
“NOTES [1] I concur with the majority's assessment that the Court of Appeals incorrectly shifted the burden onto plaintiff to state her claims in avoidance of the EALA limitation on liability.”
Violet Lapeer v. Otsego Cnty. Fair Ass'n (Mich. Ct. App. 2021).
“[MCL 691.1662(a) (emphasis added).] To summarize, the EALA precludes a participant in an equine activity from asserting a claim against an equine activity sponsor for injuries arising from an inherent risk of an equine activity.”
— Mich. Comp. Laws § 691.1662(f)(ii) — 3 cases
Amburgey v. Sauder, 605 N.W.2d 84 (Mich. Ct. App. 2000).
“[MCL 691.1662; MSA 12.418(2) (emphasis added).”
Beattie v. MICKALICH, 784 N.W.2d 38 (Mich. 2010).
“NOTES [1] I concur with the majority's assessment that the Court of Appeals incorrectly shifted the burden onto plaintiff to state her claims in avoidance of the EALA limitation on liability.”
Beattie v. Mickalich, 773 N.W.2d 748 (Mich. Ct. App. 2009).
“[MCL 691.1662(a) (emphasis added).] And, “equine activity” means, but is not limited to: (ii) Equine training or teaching activities.”
— Mich. Comp. Laws § 691.1662(g) — 5 cases
Amburgey v. Sauder, 605 N.W.2d 84 (Mich. Ct. App. 2000).
“[MCL 691.1662; MSA 12.418(2) (emphasis added).”
Violet Lapeer v. Otsego Cnty. Fair Ass'n (Mich. Ct. App. 2021).
“Engage in an equine activity includes visiting, touring, or utilizing an equine facility as part of an organized event or activity including the breeding of equines, or assisting a participant or show management. Engage in equine activity does not include spectating at an equine…”
Violet Lapeer v. Otsego Cnty. Fair Ass'n (Mich. Ct. App. 2021).
“[MCL 691.1662(a) (emphasis added).] To summarize, the EALA precludes a participant in an equine activity from asserting a claim against an equine activity sponsor for injuries arising from an inherent risk of an equine activity.”
Rebecca Goch v. the Edison Inst. (Mich. Ct. App. 2025).
“The act of “driving” is recognized as a form of participation in an equine activity (MCL 691.1662(a)). The term “drive” is typically defined to encompass directing the movement and course of a draft animal, operating a vehicle, or being transported in a vehicle, as per…”
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