Boyer v. Iowa High School Athletic Association – Case Brief
Boyer v. Iowa High School Athletic Ass’n, 152 N.W.2d 293, 260 Iowa 1061 (Iowa 1967).
Facts: Boyer attended a basketball game and was sitting in bleachers designed to fold against the wall of the gymnasium when not in use. After the game ended the section occupied by Boyer suddenly folded back throwing her to the floor, and Boyer sued the Iowa High School Athletic Association (D) for her injuries.
P pleaded her case in two counts; one charged specific acts of negligence and the other based in the doctrine of res ipsa loquitur. There was no evidence to support the specific acts of negligence but the res ipsa loquitur count was submitted to the jury. The court entered judgment in favor of P and D appealed.
Issue: A) What is the test for the application of the doctrine of res ipsa loquitur? B) If res ipsa loquitur applies, what are the consequences?
Holding and Rule: A) The test for the application of the res ipsa loquitur doctrine is: 1) exclusive control and management by defendant of the instrumentality which causes the injury, and 2) the occurrence is such as in the ordinary course of things would not happen if reasonable care had been used. B) Where res ipsa loquitur applies, an inference of negligence by the defendant is created and the burden of proof shifts to the defendant to rebut the inference.
Bleachers designed for use by spectators at athletic events do not ordinarily collapse, when used as they normally are, without negligence of those who have control over them and responsibility for their management. D had exclusive control and management of the bleachers and they had the best opportunity to discover any defect in them. D states that P had access to the bleachers immediately after the accident; however a seriously injured person could hardly be expected to examine the bleachers rather than attend to the treatment of her injuries.
Disposition: Affirmed.
Notes: This case is frequently cited incorrectly as Boyer v. Iowa High School Athletic Ass’n, 138 N.W.2d 914, 258 Iowa 285 (Iowa 1965), a former appeal of the same case to the Supreme Court of Iowa on different grounds.