Owen v. R.J.S. Safety Equipment, Inc.
Cases that cite this one
95 later published cases cite this decision. The 25 that cite it most often are listed here.
- Lux v. Cox (District Court, W.D. New York 1998)
- Waite v. County of Clinton, N.Y. (Appellate Division of the Supreme Court of New York 2023)
- Ferrari v. Bob's Canoe Rental, Inc. (Appellate Division of the Supreme Court of New York 2016)
- Weinberger v. Solomon Schechter School (Appellate Division of the Supreme Court of New York 2013)
- Weinberger v. Solomon Schechter School (Appellate Division of the Supreme Court of New York 2013)
- Demelio v. Playmakers, Inc. (New York Supreme Court 2008)
- City of Santa Barbara v. Superior Court (Cal. 2007)
- Petrie v. Bridgehampton Road Races Corp. (Appellate Division of the Supreme Court of New York 1998)
- Simoneau v. State (Appellate Division of the Supreme Court of New York 1998)
- Thomas v. Dundee Raceway Park, Inc. (District Court, N.D. New York 1995)
- Mc Duffie v. Watkins Glen International, Inc. (District Court, W.D. New York 1993)
- Brancati v. Bar-U-Farm, Inc. (Appellate Division of the Supreme Court of New York 1992)
- Katleski v. Cazenovia Golf Club, Inc. (N.Y. 2025)
- Katleski v. Cazenovia Golf Club, Inc. (N.Y. 2025)
- Kevin Grady v.Chenango Valley Central School District , Joanne Secky v. New Paltz Central School District (N.Y. 2023)
- Buffalino v. XSport Fitness (Appellate Division of the Supreme Court of New York 2022)
- Annitto v. Smithtown Cent. Sch. Dist. (Appellate Division of the Supreme Court of New York 2022)
- Bodden v. Holiday Mtn. Fun Park Inc. (Appellate Division of the Supreme Court of New York 2021)
- Jamjyan v. West Mtn. Ski Club, Inc. (Appellate Division of the Supreme Court of New York 2019)
- Calderone v. College (Appellate Division of the Supreme Court of New York 2019)
- Ward v. Stewart (District Court, N.D. New York 2018)
- Ward v. Stewart (District Court, N.D. New York 2017)
- Georgiades v. Nassau Equestrian Center at Old Mill, Inc. (Appellate Division of the Supreme Court of New York 2015)
- Rispoli v. Long Beach Union Free School District (Appellate Division of the Supreme Court of New York 2013)
- Rispoli v. Long Beach Union Free School District (Appellate Division of the Supreme Court of New York 2013)
This list shows which later cases cite this one. It does not say how they treated it, and no review of that has been done. Not a substitute for Shepard’s or KeyCite — verify before relying.
Opinion of the Court
OPINION OF THE COURT
Memorandum.
The order of the Appellate Division should be affirmed, with costs.
The record before the court on the motions for summary judgment demonstrates that plaintiffs decedent had paid a fee for the privilege of being admitted to the pit area of the Orange County Fair Speedway, where the accident that caused his death occurred. Since admission to the pit area was a necessary condition to decedent’s participation in the race, General Obligations Law § 5-326, which is operative when an owner or operator of a recreational facility has received "a fee * * * for the use of [the] facilit[y],” is applicable. We do not consider whether the decedent, who defendants claim was a professional race car driver, was a “user” of the recreational facility within the meaning of General Obligations Law § 5-326, since that issue was not raised before the trial court. Accordingly, since there is no cognizable basis for withholding application of the statute, the release the decedent signed purporting to exonerate the track owner and race promoter from liability for injury must be deemed unenforceable, and it cannot serve as a basis for dismissing plaintiffs complaint (cf., Lago v Krollage, 78 NY2d 95, 101 [General Obligations Law § 5-326 not applicable where only fee was one paid in connection with decedent’s application to become a member and licensee of a race promotion organization rather than for the use of a particular racetrack]).
Nor is the affirmative defense of assumption of risk which defendants asserted a viable ground for dismissing the
Chief Judge Wachtler and Judges Simons, Kaye, Alexander, Titone, Hancock, Jr., and Bellacosa concur.
On review of submissions pursuant to section 500.4 of the Rules of the Court of Appeals (22 NYCRR 500.4), order affirmed in a memorandum. Certified question answered in the negative.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.