Case Citation: University of Texas at Arlington v. Williams , 459 S.W. 3d 48 (Tex. 2015)
Parties: University of Texas at Arlington (UTA), Plaintiff/Appellant
Sandra and Steve Williams, Defendant/Appellee
Facts : The stadium at the University of Texas at Arlington (UTA) serves as a multipurpose community facility, which has an estimate of 12,500 seats. Sandra William and her husband, Steve Williams presented a case against UTA after Sandra fell as she was walking down the stairs. Sandra had just left a game and she was walking down the stairs, when she stopped at a guard rail separating the stands and the playing field. The gate is usually opened when the portable stairs are stationed to allow access to the field. However, this time the gate was closed and the stairs were not there. Sandra leaned against the gate for support, but it unexpectedly flew open. She fell down five feet onto the artificial turf field of the stadium, sustaining injuries to her left arm and ribs.
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Procedural History: Williams presented a premises liability suit against UTA, where she accused them of gross negligence for securing the gate with a lock and chain that were inadequate. She also accused the University of its Failure to keep the gate maintained and repair the latch when it broke. The University responded with a motion to dismiss, a general denial, and a plea to the jurisdiction, stating the recreational use and sovereign immunity statute. This statute provides that as far as the recreational use statute is in application, then it bears control over the Tort Claims Act. William, on the other hand, argued that she was not involved in a recreational activity when the accident happened, and this the recreational use statute was not applicable in this case. She went further to state that in the alternative that the statute applied, then the motion and plea by UTA to dismiss the case should be denied in the light that she had raised an issue about gross negligence by the university. The trial court was in agreement with William’s argument, and it denied the plea and motion by UTA. UTA appealed, and they were granted the petition to determine whether being a spectator of a soccer game is a recreational activity or not, based on the recreational use statute.
Issues Statements : Is it reasonable to include a spectator of a competitive sports event in the use of the recreational use statute?
Holdings : No. The activity of sports spectating is very different when compared with the activities outlined in the list of ‘recreation’ as far as the statute is concerned.
Reasoning : The applicability of the term ‘recreation’ under the recreational use statute means activities like fishing, hunting, boating, swimming, camping, pleasure diving, hiking, nature study, and any other activity that is associated with nature and outdoors enjoyment. In this case, Williams had just gone to the stadium to watch sports, and this makes the recreational use statute inapplicable for her case.
Decision : To come to a concrete decision regarding this case, the court referred to the case of City of Bellmead v. Torres, where a conclusion had been reached that the application of the recreational use statute is dependent on the particular activity that the appellant was involved in at the time of the accident. In this case, the plaintiff got injured when she was in the process of acquiring and signing forms to have her daughter released from school after the soccer match was over. When examined under the City of Bellmead, this particular activity cannot be qualified as recreational use. The fact that the accident occurred after the game was over means that Williams cannot be classified as a spectator in this case. For this reason, the recreational use statute is not applicable in this dispute.
References
LEE ANN DAUPHINOT, J. (2019). UNIV. OF TEXAS AT ARLINGT | 455 S.W.3d 640 (2013) | 20130329723 | Leagle.com. Retrieved 20 July 2019, from https://www.leagle.com/decision/intxco20130329723
Univ. of Tex. at Arlington v. Williams, 459 S.W.3d 48 | Casetext. (2019). Retrieved 20 July 2019, from https://casetext.com/case/univ-of-tex-at-arlington-v-williams-1
University Of Texas at Arlington v. Sandra Williams and Steve Williams, 13-0338 - Supreme Court of Texas Blog. (2019). Retrieved 20 July 2019, from https://data.scotxblog.com/scotx/no/13-0338
