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Rudolph v. Ariz. B.A.S.S. Fed'n - 182 Ariz. 622, 898 P.2d 1000 (Ct. App. 1995)

Rule:

A case involving a tournament organizer is more akin to an ordinary negligence action than one involving a professional defendant, such as a health care provider, for which specialized standards of care apply. The applicable standard of care, therefore, is that of a reasonably prudent person or entity under the circumstances. Expert testimony is unnecessary when the disputed subject is something that persons unskilled in the relevant area are capable of understanding and are therefore able to decide relevant fact questions without the opinions of experts.

Facts:

Grand Canyon Bass Busters (GCBB) held a fishing tournament on a crowded lake, set up the weigh-in station at a congested area, and ended the tournament at a busy time of the day. Plaintiffs' daughter, Heather, and her friend, who were not a participant in the tournament, were jet skiing on the lake when a participant, who was traveling at a high rate of speed to meet the tournament deadline, collided with the jet ski killing its occupants. Heather’s parents filed a wrongful death action against the participant and GCBB. GCBB filed a motion for summary judgment contending that they owed no duty to the deceased. The trial court granted the motion.

Issue:

Did GCBB owe a duty to the deceased?

Answer:

Yes

Conclusion:

The court reversed the trial court’s decision and held that: (1) GCBB had a duty to exercise due care in designing and conducting the tournament so as not to injure other users on the lake; (2) the relevant standard of care was that of a reasonably prudent person under the circumstances; and (3) there was sufficient evidence on the issues of breach of duty and proximate cause to withstand summary judgment.

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