Sallee v. Stewart
Annotate this CaseWhile accompanying students on a field trip to a dairy farm, a chaperone (Plaintiff) was injured when she fell through a hole in the floor of a hayloft. Plaintiff filed a negligence suit against the dairy farm's owners (Defendants). The district court granted summary judgment for Defendants, concluding that Iowa's recreational use statute barred Plaintiff's claims. The court of appeals agreed that Defendants' property was covered by the recreational use statute, that Plaintiff was engaged in a recreational purpose, and that Defendants had not willfully or maliciously failed to guard or warn against a dangerous condition, but the court found that Plaintiff could still maintain a suit against Defendants as tour guides. The Supreme Court vacated the decision of the court of appeals, reversed the judgment of the district court, and remanded, holding (1) recreational use immunity did not extend to Defendants because Plaintiff was not engaged in a recreational purpose within the scope of the statute; but (2) Plaintiff had not raised a material issue of triable fact as to whether Defendants willfully or maliciously failed to guard or warn against the presence of the hole.
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