Cunningham v. Jackson Hole Mountain Resort Corporation, 2016 U.S. App. LEXIS 22608

Cunningham v. Jackson Hole Mountain Resort Corporation, 2016 U.S. App. LEXIS 22608

Lindy Grace Cunningham; Michael Chad Cunningham, Plaintiffs – Appellants, v. Jackson Hole Mountain Resort Corporation, a Wyoming corporation, Defendant – Appellee.

No. 16-8016

UNITED STATES COURT OF APPEALS FOR THE TENTH CIRCUIT

2016 U.S. App. LEXIS 22608

December 20, 2016, Filed

PRIOR HISTORY:  [*1] (D.C. No. 2:15-CV-00007-NDF). (D. Wyo.).

COUNSEL: For LINDY GRACE CUNNINGHAM, MICHAEL CHAD CUNNINGHAM, Plaintiff – Appellant: Gerard R. Bosch, Mary Alison Floyd, Law Offices of Jerry Bosch, LLC, Wilson, WY.

For JACKSON HOLE MOUNTAIN RESORT CORPORATION, a Wyoming Corporation, Defendant – Appellee: James Kent Lubing, Lubing Law Group, Jackson, WY.

JUDGES: Before KELLY, MATHESON, and McHUGH, Circuit Judges.

OPINION BY: Carolyn B. McHugh

OPINION

ORDER AND JUDGMENT*

* This order and judgment is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1.

Lindy and Chad Cunningham sued Jackson Hole Mountain Resort Corporation (JHMR)1 for injuries Mrs. Cunningham sustained when she collided with a trail sign while skiing. The district court granted summary judgment for JHMR, concluding the Cunninghams’ claims were barred by the terms of a release Mrs. Cunningham signed when she rented ski equipment from JHMR’s ski shop. Exercising jurisdiction pursuant to 28 U.S.C. § 1291, we affirm.

1 Throughout this opinion, we use the acronym JHMR to refer to both the Jackson Hole Mountain Resort property and the corporation that owns the resort, Jackson Hole Mountain Resort Corporation.

  1. BACKGROUND

During a January 2013 vacation to Teton Village, Wyoming, Lindy Cunningham rented ski equipment from a JHMR shop located at the base of the resort’s ski area. During the rental process, Mrs. Cunningham signed a rental agreement,2 which included the following language (the release):

I [the signor] further agree to forever release, discharge, waive, [*2]  save and hold harmless, indemnify, and defend JHMR . . . from and against any and all claims, demands, causes of action, liabilities, actions, and any and all medical expenses or other related expenses, including damage to persons and property, asserted by others, by me, or on my behalf, my estate, executors, heirs, or assigns brought under any theory of legal liability, INCLUDING NEGLIGENCE, arising directly or indirectly out of my use of the facilities, ski area or ski lifts at JHMR, or my presence on JHMR premises.

2 The Cunninghams contend there is a genuine dispute of fact regarding whether Mrs. Cunningham actually signed the rental agreement because, in response to requests for admission, Mrs. Cunningham asserted she viewed the agreement on a computer screen and not in the form presented during discovery. But there is no dispute Mrs. Cunningham’s physical signature appears on the rental agreement. And there is no dispute JHMR provides the same agreement to every rental customer on a computer screen before printing a hard copy for the customer’s signature. Moreover, this evidence relates solely to the third factor in our analysis of the release’s enforceability, which requires consideration of “whether the agreement was fairly entered into.” Schutkowski v. Carey, 725 P.2d 1057, 1060 (Wyo. 1986). As explained below, Mrs. Cunningham raised arguments only with respect to the fourth factor and therefore waived the arguments for which the signature evidence would be relevant. See Richison v. Ernest Grp., Inc., 634 F.3d 1123, 1128 (10th Cir. 2011). Accordingly, the evidence does not provide a basis to reverse the district court’s grant of summary judgment.

On January 14, while skiing at JHMR, Mr. Cunningham followed behind Mrs. Cunningham, filming her on his helmet-mounted GoPro camera. Footage from the camera shows Mrs. Cunningham fall toward the right side of the trail, slide, and then collide with a trail sign. The accident severely injured Mrs. Cunningham’s spine, rendering her a quadriplegic.

The Cunninghams sued JHMR, claiming negligence, premises liability, negligent training and supervision, and loss of consortium. After limited discovery, the district court concluded the Cunninghams’ claims were barred by the release, and it therefore granted summary judgment in JHMR’s favor.

  1. DISCUSSION

[HN1] We review the district [*3]  court’s grant of summary judgment de novo. Sapone v. Grand Targhee, Inc., 308 F.3d 1096, 1100 (10th Cir. 2002). “Because this is a diversity case, we apply the substantive law of Wyoming, the forum state.” Id. Specifically, we “must ascertain and apply state law to reach the result the Wyoming Supreme Court would reach if faced with the same question.” Cooperman v. David, 214 F.3d 1162, 1164 (10th Cir. 2000). If “no state cases exist on a point, we turn to other state court decisions, federal decisions, and the general weight and trend of authority.” Grand Targhee, 308 F.3d at 1100 (citation omitted). Here, the district court concluded the release signed by Mrs. Cunningham was valid and enforceable under Wyoming law and encompassed all of the Cunninghams’ claims. In addition, the district court determined JHMR did not act willfully or wantonly.3 We affirm each of the district court’s determinations.

3 JHMR also argued the claims were barred by the Wyoming Recreation Safety Act (WRSA), Wyo. Stat. Ann. §§ 1-1-121 to -123, because Mrs. Cunningham hit a trail sign, which is an inherent risk of skiing. But the district court denied summary judgment on this basis, and neither party has appealed this determination. Accordingly, we do not address it here.

  1. Enforceability and Scope of the Release

[HN2] Wyoming courts will enforce clauses releasing parties from liability for injury or damages so long as the clause is not contrary to public policy. Schutkowski v. Carey, 725 P.2d 1057, 1059 (Wyo. 1986). And as relevant here, “[g]enerally, specific agreements absolving participants and proprietors from negligence liability during hazardous recreational activities are enforceable, subject to willful misconduct limitations.” Id.; see also Fremont Homes, Inc. v. Elmer, 974 P.2d 952, 956 (Wyo. 1999) (“Where willful and wanton [*4]  misconduct is shown, an otherwise valid release is not enforceable.”). To determine the enforceability of a particular exculpatory clause, the Wyoming Supreme Court applies a four-part test:

In reaching its determination a court considers . . . (1) whether a duty to the public exists; (2) the nature of the service performed; (3) whether the contract was fairly entered into; and (4) whether the intention of the parties is expressed in clear and unambiguous language. Only exculpatory agreements meeting these requirements are enforceable.

Schutkowski, 725 P.2d at 1060; see also Boehm v. Cody Country Chamber of Commerce, 748 P.2d 704, 710 (Wyo. 1987) (“An agreement passing scrutiny under these factors is valid, denying the signing party an action in negligence.”). In application, the Wyoming Supreme Court has essentially combined the first two factors, stating that “[a] duty to the public exists if the nature of the business or service affects the public interest and the service performed is considered an essential service.” Milligan v. Big Valley Corp., 754 P.2d 1063, 1066 (Wyo. 1988). The third factor has also been discussed in conjunction with the first two. See Schutkowski, 725 P.2d at 1060 (“The service provided by appellees was not a matter of practical necessity for any member of the public. It was not an essential service, so no decisive bargaining advantage existed.”). [*5]

On appeal, the Cunninghams make arguments related to the first three factors by asserting (1) JHMR owes a duty to the public because it operates on United States Forest Service land pursuant to a special use permit and is subject to federal regulation, (2) the release is contrary to public policy as expressed in the Wyoming Recreation Safety Act, and (3) the release unlawfully bars negligence actions arising from essential services such as the provision of emergency medical services at the JHMR clinic. But the Cunninghams did not raise these arguments before the district court. In their opposition to summary judgment, the Cunninghams focused exclusively on the fourth factor: whether the intention of the parties is expressed in clear and unambiguous language. In addition, the Cunninghams failed to present evidence to the district court in support of these new arguments, which is why they ask this court to take judicial notice of the requisite facts.4 Although the Cunninghams maintain they raised the public-duty issue below, the discussion was limited to isolated references in the facts section of their memorandum to the district court, which merely recited the ownership interest of the [*6]  Forest Service and the alleged existence of a special use permit. The Cunninghams did not provide analysis or argument to the district court related to JHMR’s public duty or the other two arguments now raised on appeal. Under these circumstances, the Cunninghams have forfeited these arguments, and we do not consider them for the first time on appeal. See Bancamerica Commercial Corp. v. Mosher Steel of Kan., Inc., 100 F.3d 792, 798 (10th Cir. 1996) (“Vague, arguable references to a point in the district court proceedings do not preserve the issue on appeal.” (alterations, ellipsis, and citation omitted)).

4 Because the Cunninghams’ proffered evidence relates only to arguments not preserved for appeal, we deny the motion for judicial notice.

We therefore limit our review to  [HN3] the fourth factor, which “requires us to determine whether the release agreement evidences the parties’ intent to abrogate negligence liability in clear and unambiguous language.” Boehm, 748 P.2d at 711. To make this determination, we must “closely scrutinize” the exculpatory clause. Schutkowski, 725 P.2d at 1060. In doing so, we must interpret the clause “using traditional contract principles and considering the meaning of the document as a whole.” Massengill v. S.M.A.R.T. Sports Med. Clinic, P.C., 996 P.2d 1132, 1135 (Wyo. 2000). In addition, “the nature of the service and the purpose of the release must be considered.” Schutkowski, 725 P.2d at 1062. Applying these principles, the district court concluded the rental agreement clearly and unambiguously released JHMR from liability for all of the Cunninghams’ [*7]  claims. We agree.

When Mrs. Cunningham signed the rental agreement, she released JHMR

from and against any and all claims, demands, causes of action, liabilities, actions, and any and all medical expenses or other related expenses, including damage to persons and property, asserted by others, by me, or on my behalf, my estate, executors, heirs, or assigns brought under any theory of legal liability, INCLUDING NEGLIGENCE, arising directly or indirectly out of my use of the facilities, ski area or ski lifts at JHMR, or my presence on JHMR premises.

.See Street v. Darwin Ranch, Inc., 75 F. Supp. 2d 1296, 1302 (D. Wyo. 1999) (“The Release blatantly and unambiguously [*8]  specifies that Plaintiff waived negligence claims against Defendant for all injuries resulting from participation in the recreational activity, making it even more clear than the exculpatory clauses found valid in Schutkowski and Milligan.” (internal cross-reference omitted)).

Nonetheless, the Cunninghams contend the release is unclear and/or ambiguous because the exculpatory language is “hidden,” the release is internally conflicted, and the release is overly broad. The Cunninghams also contend that, even if the release is clear and unambiguous, the parties mutually misunderstood the release to cover only rental-equipment-related injuries and that, by its terms, the release applies only to injuries arising from inherent hazards of skiing. We address each of these arguments in turn.

  1. “Hidden” Exculpatory Language

The Cunninghams first assert the exculpatory clause was too inconspicuous to be “clear and unambiguous.” We have found no case imposing a “conspicuousness” requirement to exculpatory clauses under Wyoming law.5 But even assuming enforcement of a sufficiently inconspicuous clause could offend public policy, the release here is not inconspicuous.

5 The only case the Cunninghams cite that identified such a requirement in the context of a liability waiver for recreational activity is  [*9] Kolosnitsyn v. Crystal Mountain, Inc., No. C08-05035-RBL, 2009 U.S. Dist. LEXIS 79111, 2009 WL 2855491 (W.D. Wash. Aug. 28, 2009). There, the district court considered whether Crystal Mountain’s liability release was conspicuous, but it did so under Washington state law, which deems exculpatory clauses “enforceable unless they violate public policy, are inconspicuous, or the negligence falls below standards established by law.” 2009 U.S. Dist. LEXIS 79111, [WL] at *3 (citing Scott v. Pac. W. Mountain Resort, 119 Wn.2d 484, 834 P.2d 6, 10 (Wash. 1992)). Unlike Washington, Wyoming deems exculpatory clauses enforceable unless they violate public policy; it does not consider the two additional exceptions to enforceability that Washington recognizes. See, e.g., Massengill v. S.M.A.R.T. Sports Med. Clinic, P.C., 996 P.2d 1132, 1136 (Wyo. 2000).

The Cunninghams maintain the exculpatory language is buried in a long block of text, written in small typeface, and presented in the rental agreement under circumstances which make it appear as though the whole agreement pertains only to equipment rental. But the district court correctly explained, “While the Release is part of the Rental Agreement, it makes up the bulk of the agreement.” The entire rental agreement fills one side of one piece of paper, with the release provision placed front and center. The release is presented under a heading that states “RENTAL WARNING, RELEASE OF LIABILITY AND INDEMNITY AGREEMENT — PLEASE READ CAREFULLY BEFORE SIGNING.” Assumption of risk and waiver of liability are addressed in the first two paragraphs of the release, and they are clearly set apart from one another. Moreover, the first sentence of the release signals that its scope is broader than the rental of equipment, as it discusses the dangers of skiing in general. The exculpatory provision also stands out because the phrase “INCLUDING NEGLIGENCE” is written in all caps. Furthermore, the last paragraph of the release states in part, “I HAVE CAREFULLY READ THIS RELEASE, UNDERSTAND [*10]  ITS CONTENTS, AND UNDERSTAND THAT THE TERMS OF THIS DOCUMENT ARE CONTRACTUAL . . . . I AM AWARE THAT I AM RELEASING CERTAIN LEGAL RIGHTS THAT I OTHERWISE MAY HAVE . . . .” While the print is necessarily small, it is readable even in the further-shrunken form presented in the record on appeal. And as the district court observed, “there is nothing to suggest that [Mrs.] Cunningham requested larger print or indicated that she could not read the release.” For these reasons, even if conspicuousness is a requirement under Wyoming law, the release here was conspicuous.

  1. Internal Conflict

The Cunninghams next cite Rowan v. Vail Holdings, Inc., 31 F. Supp. 2d 889, 899-900 (D. Colo. 1998), and argue the release is ambiguous because it is both consistent and inconsistent with the Wyoming Recreation Safety Act (WRSA). But the Cunninghams’ reliance on Rowan is misplaced. There, the court found a release ambiguous in part because it specifically released the resort of liability for all risks, including the use of ski lifts. Id. at 899. The release then stated the plaintiff assumed the inherent risks of skiing as set forth in Colorado’s Ski Safety Act, a statute that explicitly states that use of ski lifts does not qualify as an “inherent risk.” Id. Thus, the release conflicted [*11]  with the relevant statutory language.

Here, by contrast, there is no conflict between the WRSA and the types of risks or injuries JHMR listed in the release.  [HN4] The WRSA does not exempt or identify specific inherent risks; it generally defines “inherent risks” as “those dangers or conditions which are characteristic of, intrinsic to, or an integral part of any sport or recreational opportunity.” Wyo. Stat. Ann. § 1-1-122(a)(i). And the release here, unlike the release in Rowan, does not incorporate by reference the WRSA. In light of these significant differences, Rowan does not support a finding of ambiguity here.

  1. Overbreadth

Next, the Cunninghams make multiple arguments related to the alleged overbreadth of the release. First, the Cunninghams argue the release is ambiguous because “it relates to all ‘activities’ and all ‘facilities’ and all ‘premises’ on ‘each and every day’ against a wide array of entities and individuals.” Because the exculpatory clause includes broad language covering all facilities and activities at the resort at any time of year, the Cunninghams conclude “[t]here is no way possible for a person to understand what this clause actually encompasses.”

At the outset, we question whether the Cunninghams adequately [*12]  preserved this argument. The Cunninghams’ opposition to summary judgment contains only a passing reference to the issue:

The []release language appears to apply to the signator’s “presence on JHMR premises.” Theoretically, if someone left the ski hill and came back for dinner at the resort and was injured as a result of [JHMR]’s negligence this release would apply. This is not clear or unambiguous or within [the] scope of renting skis.

And the Cunninghams presented no evidence in the district court of JHMR’s ownership or operation of other facilities and activities at the resort. The Cunninghams instead attempt to introduce such evidence on appeal through their motion for judicial notice.

But even if we consider this issue, the Cunninghams’ arguments fail on the merits. The release explicitly limits JHMR’s liability for “any and all claims, demands, causes of action, liabilities, actions . . . arising directly or indirectly out of my use of the facilities, ski area or ski lifts at JHMR.” Although this language is broad, there is nothing ambiguous about it. Indeed, the Wyoming Supreme Court rejected an analogous argument when it held that a release from liability for “legal claims or legal [*13]  liability of any kind whether foreseen or unforeseen” meant precisely what it said and thus clearly barred a plaintiff’s negligence claims. Milligan, 754 P.2d at 1068.

The Cunninghams also argue the release should be deemed void because it covers a broad range of potential injuries but is presented in a rental agreement, thus leading renters to believe they are releasing only claims for injuries caused by the rental equipment, while in fact, the release covers all injuries, including those unrelated to equipment. In support of their argument, the Cunninghams cite Kolosnitsyn v. Crystal Mountain, Inc., in which the court expressed concern about a person “unwittingly” signing away his rights because the rental-agreement release might have applied to injuries related to the rental equipment alone or to injuries related to use of the ski area. No. C08-05035-RBL, 2009 U.S. Dist. LEXIS 79111, 2009 WL 2855491, at *4 (W.D. Wash. Aug. 28, 2009) (unpublished).

But the decision in Kolosnitsyn was based on facts not present here. In Kolosnitsyn, the plaintiff rented equipment from a ski shop and while skiing at an adjoining resort suffered injuries not caused by his equipment. 2009 U.S. Dist. LEXIS 79111, [WL] at *1. When he sued the resort, it invoked a release the plaintiff had signed when renting his equipment, based on the resort’s ownership [*14]  of the ski shop and the release’s waiver of claims against “the ski/snowboard shop, its employees, [and its] owners.” 2009 U.S. Dist. LEXIS 79111, [WL] at *1-2 (emphasis added). The court found the release unenforceable because it did not clearly identify the adjoining resort as the ski shop’s “owner.” 2009 U.S. Dist. LEXIS 79111, [WL] at *4. Thus, the plaintiff would not have known from the release itself that he was waiving claims against the resort, including for the resort’s own negligence. Id.

Here, by contrast, the release expressly waives claims against JHMR itself–it bars “any and all claims,” including those “arising directly or indirectly” from “use of the facilities, ski area or ski lifts at JHMR.” Thus, Kolosnitsyn does not support the Cunninghams’ position. Moreover, although neither we nor Wyoming courts have addressed this precise issue, we have concluded that an exculpatory release signed in conjunction with the rental of sporting equipment can bar claims for injuries arising out of participation in the sport but unrelated to the equipment. See Mincin v. Vail Holdings, Inc., 308 F.3d 1105, 1108, 1109, 1112-13 (10th Cir. 2002) (applying Colorado’s four-factor test that Wyoming has since adopted and concluding a release signed in connection with a mountain-bike rental barred negligence claims against resort for biker’s injuries [*15]  unrelated to the bike or other rented equipment).

The Cunninghams also argue the release should be held invalid because it applies to skiers who rent equipment, but not to skiers who bring their own. Although this argument finds some support in the Kolosnitsyn decision, 2009 U.S. Dist. LEXIS 79111, 2009 WL 2855491, at *4, it does not fit squarely within the four-factor framework established by Wyoming law. Rather, it seems to be a general appeal to public policy. While the Wyoming Supreme Court does not enforce contracts that are contrary to public policy, it also “will not invalidate a contract entered into freely by competent parties on the basis of public policy unless that policy is well settled.” Andrau v. Mich. Wis. Pipe Line Co., 712 P.2d 372, 376 (Wyo. 1986) (internal quotation marks omitted). The Cunninghams have not shown a settled public policy in Wyoming that discourages releases like JHMR’s. Moreover, the evidence shows JHMR requires its season-pass holders to sign releases identical or similar to the one signed by Mrs. Cunningham. We therefore reject this argument.

  1. Mutual Mistake and Inherent Hazards

The Cunninghams next argue that even if the release is unambiguous, it does not bar their claims for two reasons. First, the Cunninghams maintain both they and JHMR believed the release [*16]  applied only to injuries related to rental equipment and therefore the parties were mutually mistaken as to the release’s scope. But the Cunninghams also concede they did not raise this argument before the district court. We therefore decline to address the argument because it has been forfeited and the Cunninghams did not argue plain-error review. See Richison v. Ernest Grp., Inc., 634 F.3d 1123, 1128 (10th Cir. 2011).

Second, the Cunninghams briefly argue that, based on the reasoning of a Wyoming state district court in Beckwith v. Weber, Civ. Action No. 14726, the exculpatory language in the second paragraph of the release must be read to apply only to injuries arising from the “inherent hazards” discussed in the first paragraph of the release. But, as the district court concluded, Beckwith is distinguishable because the release there contained only a single sentence that did not mention a release of liability for negligence. By contrast, the release here clearly and unambiguously bars negligence claims against JHMR, not just claims arising out of the inherent risks of skiing. And even if the release could be limited to the inherent risks identified in the first paragraph of the release, such risks include “collisions with . . . man-made objects [*17]  and features.” Because Mrs. Cunningham collided with a man-made trail sign, she cannot succeed on this argument, even if the release could be read to apply only to the identified inherent risks.

In sum, we agree with the district court that the release clearly and unambiguously bars the Cunninghams’ claims. And because the ambiguity of the release was the only issue preserved for our review, we conclude the release is valid and enforceable under Wyoming law.

  1. Willful and Wanton Conduct

Finally, the Cunninghams argue the release is unenforceable because JHMR engaged in willful and wanton misconduct. See Milligan v. Big Valley Corp., 754 P.2d 1063, 1068 (Wyo. 1988) ( [HN5] “Where willful and wanton misconduct is shown, an otherwise valid release is unenforceable.”). Wyoming sets a high bar for establishing willful and wanton misconduct.

Willful and wanton misconduct is the intentional doing of an act, or an intentional failure to do an act, in reckless disregard of the consequences and under circumstances and conditions that a reasonable person would know, or have reason to know that such conduct would, in a high degree of probability, result in harm to another.

Hannifan v. Am. Nat’l Bank of Cheyenne, 2008 WY 65, 185 P.3d 679, 683 (Wyo. 2008) (emphasis omitted) (quoting Weaver v. Mitchell, 715 P.2d 1361, 1370 (Wyo. 1986)). It is “more aggravated than gross negligence.” Danculovich v. Brown, 593 P.2d 187, 191 (Wyo. 1979). “In order to [*18]  prove that an actor has engaged in willful misconduct, one must demonstrate that he acted with a state of mind that approaches intent to do harm.” Cramer v. Powder River Coal, LLC, 2009 WY 45, 204 P.3d 974, 979 (Wyo. 2009) (citation omitted).

Here, there is no evidence from which a reasonable jury could conclude JHMR acted willfully or wantonly when it placed the trail sign with which Mrs. Cunningham collided. It is undisputed that the sign has been in the same spot in substantially the same form for over thirty years. Yet there was no evidence presented that anyone other than Mrs. Cunningham has collided with the sign in that time. Although the Cunninghams’ experts criticized JHMR’s choices in placing and constructing the sign, as the district court concluded, “[a]t best, the alleged failings related to the placement and construction of the sign are negligent, not willful and wanton behavior.”

Moreover, the only case to which the Cunninghams draw an analogy–Rowan v. Vail Holdings, Inc., 31 F. Supp. 2d 889 (D. Colo. 1998)–is clearly inapposite. Rowan involved a skier who died after colliding with a picnic deck (1) that was at the bottom of a race course on which skiers “attained speeds in excess of 120 kilometers per hour,” id. at 892; (2) that was positioned such that skiers had “to make a hard left turn at the end of the course to avoid [*19]  the deck,” id. at 893-94; (3) that was unpadded, despite having been previously padded and despite available padding that easily could have been attached, id. at 893, 900; and (4) with which there had been several “close calls” and an actual injury on the same day the skier was killed and in the two days prior, id. at 900. In addition, the resort made the decedent and other skiers sign the release in the middle of the third day of their test runs, doing so only after receiving notice of multiple close calls and an actual injury, and claiming it routinely required releases but without producing evidence to support this claim. Id. at 898, 900. The present circumstances bear no similarity to the facts in Rowan. Where the trail sign here had been in place without known incident for over thirty years prior to Mrs. Cunningham’s accident, no reasonable jury could conclude JHMR engaged in willful and wanton misconduct by placing it there. Accordingly, the release is enforceable and bars the Cunninghams’ claims.6

6 Because Mr. Cunningham’s claim for loss of consortium is derivative of Mrs. Cunningham’s claims related to her injuries, his claim also fails. Massengill, 996 P.2d at 1137; Boehm v. Cody Country Chamber of Commerce, 748 P.2d 704, 710 (Wyo. 1987).

III. CONCLUSION

For the foregoing reasons, we AFFIRM the district court’s order granting summary judgment in favor of JHMR. And we DENY the Cunninghams’ motion for judicial notice.

Entered for the Court

Carolyn B. McHugh

Circuit Judge

 


Final: 2015-2016 In bound ski/board fatalities

This list is not guaranteed to be accurate. The information is found from web searches and news dispatches. Those references are part of the chart. If you have a source for information on any fatality please leave a comment or contact me. Thank you.

If this information is incorrect or incomplete please let me know.  This is up to date as of April 21, 2016. Thanks.

Skiing and Snowboarding are still safer than being in your kitchen or bathroom. This information is not to scare you away from skiing but to help you understand the risks.

Red type is natural or medical conditions that occurred inbounds on the slopes

Green Type is Fatalities while sledding at the Resort

Blue Type is a Lift Accidents

Purple Tye is Employee or Ski Patroller

2015 – 2016 Ski Season Fatalities

#

Date

State

Resort

Where

Trail Difficulty

How

Cause

Ski/ Board

Age

Sex

Home town

Helmet

Reference

Ref # 2

1

11/29/15

CA

Bear Mountain

 

 

she collided with a metal stairway

 

Ski

21

F

Jackson Township CA

 

http://rec-law.us/1HAkwAp

http://rec-law.us/1LJ13sm

2

12/7/15

WY

Jackson Hole

Moran Run

Blue

Hit tree

 

Board

23

F

Boston, MA

Y

http://rec-law.us/1OO1M1P

http://rec-law.us/1NGuZLh

3

12/15/15

CO

Steamboat

 

 

fell, landing face down in the snow

 

Ski

70

M

Louisville CO

 

http://rec-law.us/1TPTaHk

http://rec-law.us/1YksmR0

4

12/19/15

WA

Snoqualmie Pass

Silver Fir

 

tree-well

 

Ski

50

M

North Bend, WA

 

http://rec-law.us/1ZDDJG7

http://rec-law.us/1ms5yCF

5

12/22/15

WY

Jackson Hole

Sundance run

 

found inverted in a tree well

 

Ski

25

F

Jackson Hole, WY

Y

http://rec-law.us/1kwuRlK

http://rec-law.us/1mlDKjR

6

12/23/15

NY

Whiteface Lake Placid

Summit Express

Blue

fell and struck his head

blunt impact to the head

Board

26

M

Litiz, PA

N

http://rec-law.us/1P2BrJ2

 

7

12/23/15

CA

Bear Valley

 

 

 

 

Ski

71

M

 

 

http://rec-law.us/1JMVglS

http://rec-law.us/1OvzGUe

8

1/6/16

CO

Vail

 

 

 

tree well

Board

25

M

Avon, CO

 

http://rec-law.us/1ZqNv1y

http://rec-law.us/1ZYSDa6

9

1/12/16

UT

Park City

 

Intermediate

 

 

 

60

M

 

 

http://rec-law.us/1SNa4bx

 

10

1/20

CO

Keystone

Elk Run

 

Hit a tree

 

 

27

M

Boulder, CO

 

http://rec-law.us/1WtPfBv

http://rec-law.us/1or4JLh

11

1/24/16

VT

Mount Snow

Ripcord

Double Diamond

Hit Tree

Blunt Force Trauma

Board

57

M

Simsbury CT

Yes

http://rec-law.us/20r061U

http://rec-law.us/1KNgLDR

12

1/28/16

CO

Winter Park

 

 

 

 

Skier

24

M

Kalamazoo, MI

 

http://rec-law.us/1T5oZyT

 

13

1/30/16

ID

Solider Mountain

 

 

Hit building

 

Ski

14

F

Twin Falls, ID

Yes

http://rec-law.us/1NMwqDo

http://rec-law.us/1NMwqDo

14

2/3/16

PA

Blue Mountain Ski Area

 

 

 

blunt-force trauma

 

35

M

Tacoma, WA

 

http://rec-law.us/1VQlo5H

http://rec-law.us/1QL2hJ1

15

2/6

CA

Mt. Waterman

 

 

struck a tree

 

 

60

M

Winnetka, CA

 

http://rec-law.us/1RfvH4l

http://rec-law.us/1o6o30m

16

2/6

WI

Cascade Mountain Ski Hill

 

 

struck a tree

 

 

24

F

Oconto Falls, WI

No

http://rec-law.us/23RlSyy

http://rec-law.us/1LgT3js

17

2/6

UT

Park City Mtn Resort

Tombstone

 

collapsed

 

 

67

M

UT

 

http://rec-law.us/1K9Ehjw

 

18

2/15/16

VT

Burke Mountain Ski Area

Big Dipper Trail

 

collided with a tree

 

 

58

M

Watertown

No

http://rec-law.us/1mFfMPZ

http://rec-law.us/1POEu8S

19

2/16

NV

Heavenly Mountain Resort

Crossover and Comet ski runs

 

striking a tree

 

 

77

F

Madison, WI

 

http://rec-law.us/1oMH9sR

http://rec-law.us/1Oi11sG

20

2/22/16

UT

Snowbasin Ski

Janis’ trail

 

crashing into a tree,

 

 

56

M

NJ

N

http://rec-law.us/1Ukt7uB

 

21

2/22/16 (2/15)

CO

Aspen

 

Taking Lesson

Fell down

Head injury

 

68

M

CO,

 

http://rec-law.us/1SQuxxt

http://rec-law.us/1RYUVnJ

22

2/22/16

NY

Gore Mountain Ski Center

 

Double Black Diamond

struck several trees

 

 

65

M

Minerva, NY

Y

http://rec-law.us/1p1jSDG

http://rec-law.us/1VCcFnT

23

2/25

CO

Beaver Creek

 

Intermediate

Hit a sign attached to a wooden post between runs

blunt force trauma to the chest

 

39

M

Knoxville, TN

Y

http://rec-law.us/1QdvDQj

http://rec-law.us/1OFH6UP

24

2/26

MI

Crystal Mountain

Cheers Race Course

Intermediate

Lost control & slid backward

 

 

58

M

Traverse City, MI

Y

http://rec-law.us/1QdvDQj

http://rec-law.us/1n8gDJ7

25

2/27

PA

Seven Springs

Wagner Trail

 

Skier v. Skier Collision

 

 

51

M

Delmont

 

http://rec-law.us/1RA8V5e

http://rec-law.us/1LPZcnc

26

2/27

 

Squaw Valley resort

Headwall

 

fell and slid down the slope through a stand of trees, suffering multiple injuries

 

 

62

F

Olympic Valley

Y

http://rec-law.us/1Qh8MDD

http://rec-law.us/1Qh8MDD

27

3/1

CO

Breckenridge Ski Resort

Sundown

intermediate

he collided with another skier, lost control and ran into a tree

blunt force trauma injuries

 

26

M

Breckenridge, CO

N

http://rec-law.us/24BbQ4W

http://rec-law.us/1Slbxq4

28

 

 

Beaver Mountain Ski Resort

 

 

struck a tree

 

 

18

M

Camano Island, WA

 

http://rec-law.us/1TeeLg2

http://rec-law.us/1pqgmD5

 

3/6

WI

Cascade Mountain Ski Hill

 

 

running into a tree

 

 

 

F

Oconto Falls, WI

N

http://rec-law.us/21NEvov

 

30

3/6

NV

Mt. Rose Ski Tahoe

Galena run

 

reportedly fallen or collapsed

 

 

43

M

Reno, NV

 

http://rec-law.us/1SCRgwi

http://rec-law.us/1UYgTbw

31

3/9

CO

Telluride Ski Resort

Gold Hill

 

lost his skis and tumbled down a steep, wooded terrain

 

 

49

M

Colorado Springs, CO

 

http://rec-law.us/1SCRNOV

 

32

3/9

CO

Copper Mountain

American Flyer

Intermediate

hit a tree

blunt force trauma injuries

 

19

M

Arlington, VA

Y

http://rec-law.us/1UiqHfC

http://rec-law.us/1RDR0Z3

33

 

MT

 

 

 

in some trees near a ski lift

 

 

82

M

CA

 

 rec-law.us/1P223JC

 

34

3/19

CO

Telluride

Coonskin

Black Diamond

skis detached from his boots

crashed into trees

 

69

M

Greenwood, S.C.

 

http://rec-law.us/1PkTF86

http://rec-law.us/1Mxk4Qr

35

3/20

UT

Snowbird

Chip’s Run

 

 

hit a rock before losing control and colliding with the tree

 

57

M

 

 

http://rec-law.us/22s5Wog

http://rec-law.us/1o2dk6Q

36

3/24

CO

Steamboat Ski Area

Nastar Course

 

Fell

 

 

 

M

 

 

http://rec-law.us/1pBsUqX

http://rec-law.us/1UkfUTM

37

3/27

NH

Cannon Mtn

Upper Ravine Trail

 

sharp turn and struck a tree

Massive head trauma

 

29

M

Holden, MA

N

http://rec-law.us/1ZGeNNQ

http://rec-law.us/1ohdGXo

38

4/2

UT

Park City

 

Advanced

collided with a tree

 

 

48

M

Aspen, CO

 

http://rec-law.us/1UPNphr

http://rec-law.us/1V4mVbn

39

4/4

CO

Breckenridge

Tiger

Expert

Collided with another skier

 

 

43

M

Randolph, NJ

 

http://rec-law.us/23earj6

http://rec-law.us/1UTCSSn

40

4/6

CO

Breckenridge

Claimjumper

Intermediate

snowboarder collided with a tree

blunt force trauma

Board

32

M

 

Y

http://rec-law.us/1WlGz2t

http://rec-law.us/1SdftL9

41

4/9

ID

Bald Mountain Ski Area

Upper Greyhawk

 

speed flying

 

Ski

24

M

 

 

http://rec-law.us/1WBxSBf

http://rec-law.us/26cPR4Z

42

4/20

CO

Breckenridge Ski Area

Monte Cristo

 

hitting a tree

blunt force trauma injuries

Ski

20

F

Denver, CO

Y

http://rec-law.us/1YTB0qR

http://rec-law.us/1VSkLwL

 

 If you cannot read the entire chart you can download a PDF here: 2015 – 2016 Ski Season Deaths 6.15.16

Our condolences go to the families of the deceased. Our thoughts extend to the families and staff at the ski areas who have to deal with these tragedies.

If you cannot read the entire chart you can download it here.

What do you think? Leave a comment.

If you like this let your friends know or post it on FB, Twitter or LinkedIn

Copyright 2016 Recreation Law (720) Edit Law

Email: Rec-law@recreation-law.com

Google+: +Recreation

Twitter: RecreationLaw

Facebook: Rec.Law.Now

Facebook Page: Outdoor Recreation & Adventure Travel Law

Blog: www.recreation-law.com

Mobile Site: http://m.recreation-law.com

#AdventureTourism, #AdventureTravelLaw, #AdventureTravelLawyer, #AttorneyatLaw, #Backpacking, #BicyclingLaw, #Camps, #ChallengeCourse, #ChallengeCourseLaw, #ChallengeCourseLawyer, #CyclingLaw, #FitnessLaw, #FitnessLawyer, #Hiking, #HumanPowered, #HumanPoweredRecreation, #IceClimbing, #JamesHMoss, #JimMoss, #Law, #Mountaineering, #Negligence, #OutdoorLaw, #OutdoorRecreationLaw, #OutsideLaw, #OutsideLawyer, #RecLaw, #Rec-Law, #RecLawBlog, #Rec-LawBlog, #RecLawyer, RecreationalLawyer, #RecreationLaw, #RecreationLawBlog, #RecreationLawcom, #Recreation-Lawcom, #Recreation-Law.com, #RiskManagement, #RockClimbing, #RockClimbingLawyer, #RopesCourse, #RopesCourseLawyer, #SkiAreas, #Skiing, #SkiLaw, #Snowboarding, #SummerCamp, #Tourism, #TravelLaw, #YouthCamps, #ZipLineLawyer, Skiing, Snowboarding, Fatality, Ski Area, Tubing, Chair Lift,  Jackson Hole, Steamboat Springs Ski Resort, Snoqualmie Pass, Mount Snow, Park City, Vail, Bear Valley, Whiteface, Snoqualmie Pass, Burke Mountain Ski Area, Park City Mtn Resort, Cascade Mountain Ski Hill, Mt. Waterman, Blue Mountain Ski Area, Solider Mountain, Solider Mountain, Winter Park, Aspen, Snowbasin, Heavenly Mountain, Burke Mountain, Park City, Cascade Mountain, Blue Mountain, Mt. Waterman, Squaw Valley resort,

 


2015-2016 In bound ski/board fatalities

This list is not guaranteed to be accurate. The information is found from web searches and news dispatches. Those references are part of the chart. If you have a source for information on any fatality please leave a comment or contact me. Thank you.

If this information is incorrect or incomplete please let me know.  This is up to date as of April 21, 2016. Thanks.

Skiing and Snowboarding are still safer than being in your kitchen or bathroom. This information is not to scare you away from skiing but to help you understand the risks.

Red type is natural or medical conditions that occurred inbounds on the slopes

Green Type is Fatalities while sledding at the Resort

Blue Type is a Lift Accidents

Purple Tye is Employee or Ski Patroller

2015 – 2016 Ski Season Fatalities

#

Date

State

Resort

Where

Trail Difficulty

How

Cause

Ski/ Board

Age

Sex

Home town

Helmet

Reference

Ref # 2

1

11/29/15

CA

Bear Mountain

 

 

she collided with a metal stairway

 

Ski

21

F

Jackson Township CA

 

http://rec-law.us/1HAkwAp

http://rec-law.us/1LJ13sm

2

12/7/15

WY

Jackson Hole

Moran Run

Blue

Hit tree

 

Board

23

F

Boston, MA

Y

http://rec-law.us/1OO1M1P

http://rec-law.us/1NGuZLh

3

12/15/15

CO

Steamboat

 

 

fell, landing face down in the snow

 

Ski

70

M

Louisville CO

 

http://rec-law.us/1TPTaHk

http://rec-law.us/1YksmR0

4

12/19/15

WA

Snoqualmie Pass

Silver Fir

 

tree-well

 

Ski

50

M

North Bend, WA

 

http://rec-law.us/1ZDDJG7

http://rec-law.us/1ms5yCF

5

12/22/15

WY

Jackson Hole

Sundance run

 

found inverted in a tree well

 

Ski

25

F

Jackson Hole, WY

Y

http://rec-law.us/1kwuRlK

http://rec-law.us/1mlDKjR

6

12/23/15

NY

Whiteface Lake Placid

Summit Express

Blue

fell and struck his head

blunt impact to the head

Board

26

M

Litiz, PA

N

http://rec-law.us/1P2BrJ2

 

7

12/23/15

CA

Bear Valley

 

 

 

 

Ski

71

M

 

 

http://rec-law.us/1JMVglS

http://rec-law.us/1OvzGUe

8

1/6/16

CO

Vail

 

 

 

tree well

Board

25

M

Avon, CO

 

http://rec-law.us/1ZqNv1y

http://rec-law.us/1ZYSDa6

9

1/12/16

UT

Park City

 

Intermediate

 

 

 

60

M

 

 

http://rec-law.us/1SNa4bx

 

10

1/20

CO

Keystone

Elk Run

 

Hit a tree

 

 

27

M

Boulder, CO

 

http://rec-law.us/1WtPfBv

http://rec-law.us/1or4JLh

11

1/24/16

VT

Mount Snow

Ripcord

Double Diamond

Hit Tree

Blunt Force Trauma

Board

57

M

Simsbury CT

Yes

http://rec-law.us/20r061U

http://rec-law.us/1KNgLDR

12

1/28/16

CO

Winter Park

 

 

 

 

Skier

24

M

Kalamazoo, MI

 

http://rec-law.us/1T5oZyT

 

13

1/30/16

ID

Solider Mountain

 

 

Hit building

 

Ski

14

F

Twin Falls, ID

Yes

http://rec-law.us/1NMwqDo

http://rec-law.us/1NMwqDo

14

2/3/16

PA

Blue Mountain Ski Area

 

 

 

blunt-force trauma

 

35

M

Tacoma, WA

 

http://rec-law.us/1VQlo5H

http://rec-law.us/1QL2hJ1

15

2/6

CA

Mt. Waterman

 

 

struck a tree

 

 

60

M

Winnetka, CA

 

http://rec-law.us/1RfvH4l

http://rec-law.us/1o6o30m

16

2/6

WI

Cascade Mountain Ski Hill

 

 

struck a tree

 

 

24

F

Oconto Falls, WI

No

http://rec-law.us/23RlSyy

http://rec-law.us/1LgT3js

17

2/6

UT

Park City Mtn Resort

Tombstone

 

collapsed

 

 

67

M

UT

 

http://rec-law.us/1K9Ehjw

 

18

2/15/16

VT

Burke Mountain Ski Area

Big Dipper Trail

 

collided with a tree

 

 

58

M

Watertown

No

http://rec-law.us/1mFfMPZ

http://rec-law.us/1POEu8S

19

2/16

NV

Heavenly Mountain Resort

Crossover and Comet ski runs

 

striking a tree

 

 

77

F

Madison, WI

 

http://rec-law.us/1oMH9sR

http://rec-law.us/1Oi11sG

20

2/22/16

UT

Snowbasin Ski

Janis’ trail

 

crashing into a tree,

 

 

56

M

NJ

N

http://rec-law.us/1Ukt7uB

 

21

2/22/16 (2/15)

CO

Aspen

 

Taking Lesson

Fell down

Head injury

 

68

M

CO,

 

http://rec-law.us/1SQuxxt

http://rec-law.us/1RYUVnJ

22

2/22/16

NY

Gore Mountain Ski Center

 

Double Black Diamond

struck several trees

 

 

65

M

Minerva, NY

Y

http://rec-law.us/1p1jSDG

http://rec-law.us/1VCcFnT

23

2/25

CO

Beaver Creek

 

Intermediate

Hit a sign attached to a wooden post between runs

blunt force trauma to the chest

 

39

M

Knoxville, TN

Y

http://rec-law.us/1QdvDQj

http://rec-law.us/1OFH6UP

24

2/26

MI

Crystal Mountain

Cheers Race Course

Intermediate

Lost control & slid backward

 

 

58

M

Traverse City, MI

Y

http://rec-law.us/1QdvDQj

http://rec-law.us/1n8gDJ7

25

2/27

PA

Seven Springs

Wagner Trail

 

Skier v. Skier Collision

 

 

51

M

Delmont

 

http://rec-law.us/1RA8V5e

http://rec-law.us/1LPZcnc

26

2/27

 

Squaw Valley resort

Headwall

 

fell and slid down the slope through a stand of trees, suffering multiple injuries

 

 

62

F

Olympic Valley

Y

http://rec-law.us/1Qh8MDD

http://rec-law.us/1Qh8MDD

27

3/1

CO

Breckenridge Ski Resort

Sundown

intermediate

he collided with another skier, lost control and ran into a tree

blunt force trauma injuries

 

26

M

Breckenridge, CO

N

http://rec-law.us/24BbQ4W

http://rec-law.us/1Slbxq4

28

 

 

Beaver Mountain Ski Resort

 

 

struck a tree

 

 

18

M

Camano Island, WA

 

http://rec-law.us/1TeeLg2

http://rec-law.us/1pqgmD5

 

3/6

WI

Cascade Mountain Ski Hill

 

 

running into a tree

 

 

 

F

Oconto Falls, WI

N

http://rec-law.us/21NEvov

 

30

3/6

NV

Mt. Rose Ski Tahoe

Galena run

 

reportedly fallen or collapsed

 

 

43

M

Reno, NV

 

http://rec-law.us/1SCRgwi

http://rec-law.us/1UYgTbw

31

3/9

CO

Telluride Ski Resort

Gold Hill

 

lost his skis and tumbled down a steep, wooded terrain

 

 

49

M

Colorado Springs, CO

 

http://rec-law.us/1SCRNOV

 

32

3/9

CO

Copper Mountain

American Flyer

Intermediate

hit a tree

blunt force trauma injuries

 

19

M

Arlington, VA

Y

http://rec-law.us/1UiqHfC

http://rec-law.us/1RDR0Z3

33

 

MT

 

 

 

in some trees near a ski lift

 

 

82

M

CA

 

 rec-law.us/1P223JC

 

34

3/19

CO

Telluride

Coonskin

Black Diamond

skis detached from his boots

crashed into trees

 

69

M

Greenwood, S.C.

 

http://rec-law.us/1PkTF86

http://rec-law.us/1Mxk4Qr

35

3/20

UT

Snowbird

Chip’s Run

 

 

hit a rock before losing control and colliding with the tree

 

57

M

 

 

http://rec-law.us/22s5Wog

http://rec-law.us/1o2dk6Q

36

3/24

CO

Steamboat Ski Area

Nastar Course

 

Fell

 

 

 

M

 

 

http://rec-law.us/1pBsUqX

http://rec-law.us/1UkfUTM

37

3/27

NH

Cannon Mtn

Upper Ravine Trail

 

sharp turn and struck a tree

Massive head trauma

 

29

M

Holden, MA

N

http://rec-law.us/1ZGeNNQ

http://rec-law.us/1ohdGXo

38

4/2

UT

Park City

 

Advanced

collided with a tree

 

 

48

M

Aspen, CO

 

http://rec-law.us/1UPNphr

http://rec-law.us/1V4mVbn

39

4/4

CO

Breckenridge

Tiger

Expert

Collided with another skier

 

 

43

M

Randolph, NJ

 

http://rec-law.us/23earj6

http://rec-law.us/1UTCSSn

40

4/6

CO

Breckenridge

Claimjumper

Intermediate

snowboarder collided with a tree

blunt force trauma

Board

32

M

 

Y

http://rec-law.us/1WlGz2t

http://rec-law.us/1SdftL9

41

4/9

ID

Bald Mountain Ski Area

Upper Greyhawk

 

speed flying

 

Ski

24

M

 

 

http://rec-law.us/1WBxSBf

http://rec-law.us/26cPR4Z

 

2015 – 2016 Ski Season Deaths

Our condolences go to the families of the deceased. Our thoughts extend to the families and staff at the ski areas who have to deal with these tragedies.

If you cannot read the entire chart you can download it here.

What do you think? Leave a comment.

If you like this let your friends know or post it on FB, Twitter or LinkedIn

Copyright 2016 Recreation Law (720) Edit Law

Email: Rec-law@recreation-law.com

Google+: +Recreation

Twitter: RecreationLaw

Facebook: Rec.Law.Now

Facebook Page: Outdoor Recreation & Adventure Travel Law

Blog: www.recreation-law.com

Mobile Site: http://m.recreation-law.com

#AdventureTourism, #AdventureTravelLaw, #AdventureTravelLawyer, #AttorneyatLaw, #Backpacking, #BicyclingLaw, #Camps, #ChallengeCourse, #ChallengeCourseLaw, #ChallengeCourseLawyer, #CyclingLaw, #FitnessLaw, #FitnessLawyer, #Hiking, #HumanPowered, #HumanPoweredRecreation, #IceClimbing, #JamesHMoss, #JimMoss, #Law, #Mountaineering, #Negligence, #OutdoorLaw, #OutdoorRecreationLaw, #OutsideLaw, #OutsideLawyer, #RecLaw, #Rec-Law, #RecLawBlog, #Rec-LawBlog, #RecLawyer, RecreationalLawyer, #RecreationLaw, #RecreationLawBlog, #RecreationLawcom, #Recreation-Lawcom, #Recreation-Law.com, #RiskManagement, #RockClimbing, #RockClimbingLawyer, #RopesCourse, #RopesCourseLawyer, #SkiAreas, #Skiing, #SkiLaw, #Snowboarding, #SummerCamp, #Tourism, #TravelLaw, #YouthCamps, #ZipLineLawyer, Skiing, Snowboarding, Fatality, Ski Area, Tubing, Chair Lift,  Jackson Hole, Steamboat Springs Ski Resort, Snoqualmie Pass, Mount Snow, Park City, Vail, Bear Valley, Whiteface, Snoqualmie Pass, Burke Mountain Ski Area, Park City Mtn Resort, Cascade Mountain Ski Hill, Mt. Waterman, Blue Mountain Ski Area, Solider Mountain, Solider Mountain, Winter Park, Aspen, Snowbasin, Heavenly Mountain, Burke Mountain, Park City, Cascade Mountain, Blue Mountain, Mt. Waterman, Squaw Valley resort,

 


2015-2016 In bound ski/board fatalities

This list is not guaranteed to be accurate. The information is found from web searches and news dispatches. Those references are part of the chart. If you have a source for information on any fatality please leave a comment or contact me. Thank you.

If this information is incorrect or incomplete please let me know.  This is up to date as of March 21, 2016. Thanks.

Skiing and Snowboarding are still safer than being in your kitchen or bathroom. This information is not to scare you away from skiing but to help you understand the risks.

Red type is natural or medical conditions that occurred inbounds on the slopes

Green Type is Fatalities while sledding at the Resort

Blue Type is a Lift Accidents

Purple Tye is Employee or Ski Patroller

2015 – 2016 Ski Season Fatalities

#

Date

State

Resort

Where

Trail Difficulty

How

Cause

Ski/ Board

Age

Sex

Home town

Helmet

Reference

Ref # 2

1

11/29/15

CA

Bear Mountain

 

 

she collided with a metal stairway

 

Ski

21

F

Jackson Township CA

 

http://rec-law.us/1HAkwAp

http://rec-law.us/1LJ13sm

2

12/7/15

WY

Jackson Hole

Moran Run

Blue

Hit tree

 

Board

23

F

Boston, MA

Y

http://rec-law.us/1OO1M1P

http://rec-law.us/1NGuZLh

3

12/15/15

CO

Steamboat

 

 

fell, landing face down in the snow

 

Ski

70

M

Louisville CO

 

http://rec-law.us/1TPTaHk

http://rec-law.us/1YksmR0

4

12/19/15

WA

Snoqualmie Pass

Silver Fir

 

tree-well

 

Ski

50

M

North Bend, WA

 

http://rec-law.us/1ZDDJG7

http://rec-law.us/1ms5yCF

5

12/22/15

WY

Jackson Hole

Sundance run

 

found inverted in a tree well

 

Ski

25

F

Jackson Hole, WY

Y

http://rec-law.us/1kwuRlK

http://rec-law.us/1mlDKjR

6

12/23/15

NY

Whiteface Lake Placid

Summit Express

Blue

fell and struck his head

blunt impact to the head

Board

26

M

Litiz, PA

N

http://rec-law.us/1P2BrJ2

 

7

12/23/15

CA

Bear Valley

 

 

 

 

Ski

71

M

 

 

http://rec-law.us/1JMVglS

http://rec-law.us/1OvzGUe

8

1/6/16

CO

Vail

 

 

 

tree well

Board

25

M

Avon, CO

 

http://rec-law.us/1ZqNv1y

http://rec-law.us/1ZYSDa6

9

1/12/16

UT

Park City

 

Intermediate

 

 

 

60

M

 

 

http://rec-law.us/1SNa4bx

 

10

1/20

CO

Keystone

Elk Run

 

Hit a tree

 

 

27

M

Boulder, CO

 

http://rec-law.us/1WtPfBv

http://rec-law.us/1or4JLh

11

1/24/16

VT

Mount Snow

Ripcord

Double Diamond

Hit Tree

Blunt Force Trauma

Board

57

M

Simsbury CT

Yes

http://rec-law.us/20r061U

http://rec-law.us/1KNgLDR

12

1/28/16

CO

Winter Park

 

 

 

 

Skier

24

M

Kalamazoo, MI

 

http://rec-law.us/1T5oZyT

 

13

1/30/16

ID

Solider Mountain

 

 

Hit building

 

Ski

14

F

Twin Falls, ID

Yes

http://rec-law.us/1NMwqDo

http://rec-law.us/1NMwqDo

14

2/3/16

PA

Blue Mountain Ski Area

 

 

 

blunt-force trauma

 

35

M

Tacoma, WA

 

http://rec-law.us/1VQlo5H

http://rec-law.us/1QL2hJ1

15

2/6

CA

Mt. Waterman

 

 

struck a tree

 

 

60

M

Winnetka, CA

 

http://rec-law.us/1RfvH4l

http://rec-law.us/1o6o30m

16

2/6

WI

Cascade Mountain Ski Hill

 

 

struck a tree

 

 

24

F

Oconto Falls, WI

No

http://rec-law.us/23RlSyy

http://rec-law.us/1LgT3js

17

2/6

UT

Park City Mtn Resort

Tombstone

 

collapsed

 

 

67

M

UT

 

http://rec-law.us/1K9Ehjw

 

18

2/15/16

VT

Burke Mountain Ski Area

Big Dipper Trail

 

collided with a tree

 

 

58

M

Watertown

No

http://rec-law.us/1mFfMPZ

http://rec-law.us/1POEu8S

19

2/16

NV

Heavenly Mountain Resort

Crossover and Comet ski runs

 

striking a tree

 

 

77

F

Madison, WI

 

http://rec-law.us/1oMH9sR

http://rec-law.us/1Oi11sG

20

2/22/16

UT

Snowbasin Ski

Janis’ trail

 

crashing into a tree,

 

 

56

M

NJ

N

http://rec-law.us/1Ukt7uB

 

21

2/22/16 (2/15)

CO

Aspen

 

Taking Lesson

Fell down

Head injury

 

68

M

CO,

 

http://rec-law.us/1SQuxxt

http://rec-law.us/1RYUVnJ

22

2/22/16

NY

Gore Mountain Ski Center

 

Double Black Diamond

struck several trees

 

 

65

M

Minerva, NY

Y

http://rec-law.us/1p1jSDG

http://rec-law.us/1VCcFnT

23

2/25

CO

Beaver Creek

 

Intermediate

Hit a sign attached to a wooden post between runs

blunt force trauma to the chest

 

39

M

Knoxville, TN

Y

http://rec-law.us/1QdvDQj

http://rec-law.us/1OFH6UP

24

2/26

MI

Crystal Mountain

Cheers Race Course

Intermediate

Lost control & slid backward

 

 

58

M

Traverse City, MI

Y

http://rec-law.us/1QdvDQj

http://rec-law.us/1n8gDJ7

25

2/27

PA

Seven Springs

Wagner Trail

 

Skier v. Skier Collision

 

 

51

M

Delmont

 

http://rec-law.us/1RA8V5e

http://rec-law.us/1LPZcnc

26

2/27

 

Squaw Valley resort

Headwall

 

fell and slid down the slope through a stand of trees, suffering multiple injuries

 

 

62

F

Olympic Valley

Y

http://rec-law.us/1Qh8MDD

http://rec-law.us/1Qh8MDD

27

3/1

CO

Breckenridge Ski Resort

Sundown

intermediate

he collided with another skier, lost control and ran into a tree

blunt force trauma injuries

 

26

M

Breckenridge, CO

N

http://rec-law.us/24BbQ4W

http://rec-law.us/1Slbxq4

28

 

 

Beaver Mountain Ski Resort

 

 

struck a tree

 

 

18

M

Camano Island, WA

 

http://rec-law.us/1TeeLg2

http://rec-law.us/1pqgmD5

 

3/6

WI

Cascade Mountain Ski Hill

 

 

running into a tree

 

 

 

F

Oconto Falls, WI

N

http://rec-law.us/21NEvov

 

30

3/6

NV

Mt. Rose Ski Tahoe

Galena run

 

reportedly fallen or collapsed

 

 

43

M

Reno, NV

 

http://rec-law.us/1SCRgwi

http://rec-law.us/1UYgTbw

31

3/9

CO

Telluride Ski Resort

Gold Hill

 

lost his skis and tumbled down a steep, wooded terrain

 

 

49

M

Colorado Springs, CO

 

http://rec-law.us/1SCRNOV

 

32

3/9

CO

Copper Mountain

American Flyer

Intermediate

hit a tree

blunt force trauma injuries

 

19

M

Arlington, VA

Y

http://rec-law.us/1UiqHfC

http://rec-law.us/1RDR0Z3

33

 

MT

 

 

 

in some trees near a ski lift

 

 

82

M

CA

 

 rec-law.us/1P223JC

 

34

3/19

CO

Telluride

Coonskin

Black Diamond

skis detached from his boots

crashed into trees

 

69

M

Greenwood, S.C.

 

http://rec-law.us/1PkTF86

http://rec-law.us/1Mxk4Qr

35

3/20

UT

Snowbird

Chip’s Run

 

 

hitting a rock

 

55

m

 

 

http://rec-law.us/22s5Wog

http://rec-law.us/1o2dk6Q

Download a PDF of this chart here.

Our condolences go to the families of the deceased. Our thoughts extend to the families and staff at the ski areas who have to deal with these tragedies.

What do you think? Leave a comment.

If you like this let your friends know or post it on FB, Twitter or LinkedIn

Copyright 2016 Recreation Law (720) Edit Law

Email: Rec-law@recreation-law.com

Google+: +Recreation

Twitter: RecreationLaw

Facebook: Rec.Law.Now

Facebook Page: Outdoor Recreation & Adventure Travel Law

Blog: www.recreation-law.com

Mobile Site: http://m.recreation-law.com

#AdventureTourism, #AdventureTravelLaw, #AdventureTravelLawyer, #AttorneyatLaw, #Backpacking, #BicyclingLaw, #Camps, #ChallengeCourse, #ChallengeCourseLaw, #ChallengeCourseLawyer, #CyclingLaw, #FitnessLaw, #FitnessLawyer, #Hiking, #HumanPowered, #HumanPoweredRecreation, #IceClimbing, #JamesHMoss, #JimMoss, #Law, #Mountaineering, #Negligence, #OutdoorLaw, #OutdoorRecreationLaw, #OutsideLaw, #OutsideLawyer, #RecLaw, #Rec-Law, #RecLawBlog, #Rec-LawBlog, #RecLawyer, #RecreationalLawyer, #RecreationLaw, #RecreationLawBlog, #RecreationLawcom, #Recreation-Lawcom, #Recreation-Law.com, #RiskManagement, #RockClimbing, #RockClimbingLawyer, #RopesCourse, #RopesCourseLawyer, #SkiAreas, #Skiing, #SkiLaw, #Snowboarding, #SummerCamp, #Tourism, #TravelLaw, #YouthCamps, #ZipLineLawyer, Skiing, Snowboarding, Fatality, Ski Area, Tubing, Chair Lift,  Jackson Hole, Steamboat Springs Ski Resort, Snoqualmie Pass, Mount Snow, Park City,

Our condolences go to the families of the deceased. Our thoughts extend to the families and staff at the ski areas who have to deal with these tragedies.

If you cannot read the entire chart you can download it here.

What do you think? Leave a comment.

If you like this let your friends know or post it on FB, Twitter or LinkedIn

Copyright 2016 Recreation Law (720) Edit Law

Email: Rec-law@recreation-law.com

Google+: +Recreation

Twitter: RecreationLaw

Facebook: Rec.Law.Now

Facebook Page: Outdoor Recreation & Adventure Travel Law

Blog: www.recreation-law.com

Mobile Site: http://m.recreation-law.com

Vail, Bear Valley, Whiteface, Snoqualmie Pass, Burke Mountain Ski Area, Park City Mtn Resort, Cascade Mountain Ski Hill, Mt. Waterman, Blue Mountain Ski Area, Solider Mountain, Solider Mountain, Winter Park, Aspen, Snowbasin, Heavenly Mountain, Burke Mountain, Park City, Cascade Mountain, Blue Mountain, Mt. Waterman, Squaw Valley resort,

 


2015-2016 In bound ski/board fatalities

This list is not guaranteed to be accurate. The information is found from web searches and news dispatches. Those references are part of the chart. If you have a source for information on any fatality please leave a comment or contact me. Thank you.

If this information is incorrect or incomplete please let me know.  This is up to date as of March 1, 2016. Thanks.

Skiing and Snowboarding are still safer than being in your kitchen or bathroom. This information is not to scare you away from skiing but to help you understand the risks.

Red type is natural or medical conditions that occurred inbounds on the slopes

Green Type is Fatalities while sledding at the Resort

Blue Type is a Lift Accidents

Purple Tye is Employee or Ski Patroller

2015 – 2016 Ski Season Fatalities

#

Date

State

Resort

Where

Trail Difficulty

How

Cause

Ski/ Board

Age

Sex

Home town

Helmet

Reference

Ref # 2

1

11/29/15

CA

Bear Mountain

 

 

she collided with a metal stairway

 

Ski

21

F

Jackson Township CA

 

http://rec-law.us/1HAkwAp

http://rec-law.us/1LJ13sm

2

12/7/15

WY

Jackson Hole

Moran Run

Blue

Hit tree

 

Board

23

F

Boston, MA

Y

http://rec-law.us/1OO1M1P

http://rec-law.us/1NGuZLh

3

12/15/15

CO

Steamboat

 

 

fell, landing face down in the snow

 

Ski

70

M

Louisville CO

 

http://rec-law.us/1TPTaHk

http://rec-law.us/1YksmR0

4

12/19/15

WA

Snoqualmie Pass

Silver Fir

 

tree-well

 

Ski

50

M

North Bend, WA

 

http://rec-law.us/1ZDDJG7

http://rec-law.us/1ms5yCF

5

12/22/15

WY

Jackson Hole

Sundance run

 

found inverted in a tree well

 

Ski

25

F

Jackson Hole, WY

Y

http://rec-law.us/1kwuRlK

http://rec-law.us/1mlDKjR

6

12/23/15

NY

Whiteface Lake Placid

Summit Express

Blue

fell and struck his head

blunt impact to the head

Board

26

M

Litiz, PA

N

http://rec-law.us/1P2BrJ2

 

7

12/23/15

CA

Bear Valley

 

 

 

 

Ski

71

M

 

 

http://rec-law.us/1JMVglS

http://rec-law.us/1OvzGUe

8

1/6/16

CO

Vail

 

 

 

tree well

Board

25

M

Avon, CO

 

http://rec-law.us/1ZqNv1y

http://rec-law.us/1ZYSDa6

9

1/12/16

UT

Park City

 

Intermediate

 

 

 

60

M

 

 

http://rec-law.us/1SNa4bx

 

10

1/20

CO

Keystone

Elk Run

 

Hit a tree

 

 

27

M

Boulder, CO

 

http://rec-law.us/1WtPfBv

http://rec-law.us/1or4JLh

11

1/24/16

VT

Mount Snow

Ripcord

Double Diamond

Hit Tree

Blunt Force Trauma

Board

57

M

Simsbury CT

Yes

http://rec-law.us/20r061U

http://rec-law.us/1KNgLDR

12

1/28/16

CO

Winter Park

 

 

 

 

Skier

24

M

Kalamazoo, MI

 

http://rec-law.us/1T5oZyT

 

13

1/30/16

ID

Solider Mountain

 

 

Hit building

 

Ski

14

F

Twin Falls, ID

Yes

http://rec-law.us/1NMwqDo

http://rec-law.us/1NMwqDo

14

2/3/16

PA

Blue Mountain Ski Area

 

 

 

blunt-force trauma

 

35

M

Tacoma, WA

 

http://rec-law.us/1VQlo5H

http://rec-law.us/1QL2hJ1

15

2/6

CA

Mt. Waterman

 

 

struck a tree

 

 

60

M

Winnetka, CA

 

http://rec-law.us/1RfvH4l

http://rec-law.us/1o6o30m

16

2/6

WI

Cascade Mountain Ski Hill

 

 

struck a tree

 

 

24

F

Oconto Falls, WI

No

http://rec-law.us/23RlSyy

http://rec-law.us/1LgT3js

17

2/6

UT

Park City Mtn Resort

Tombstone

 

collapsed

 

 

67

M

UT

 

http://rec-law.us/1K9Ehjw

 

18

2/15/16

VT

Burke Mountain Ski Area

Big Dipper Trail

 

collided with a tree

 

 

58

M

Watertown

No

http://rec-law.us/1mFfMPZ

http://rec-law.us/1POEu8S

19

2/16

NV

Heavenly Mountain Resort

Crossover and Comet ski runs

 

striking a tree

 

 

77

F

Madison, WI

 

http://rec-law.us/1oMH9sR

http://rec-law.us/1Oi11sG

20

2/22/16

UT

Snowbasin Ski

Janis’ trail

 

crashing into a tree,

 

 

56

M

NJ

N

http://rec-law.us/1Ukt7uB

 

21

2/22/16 (2/15)

CO

Aspen

 

Taking Lesson

Fell down

Head injury

 

68

M

CO,

 

http://rec-law.us/1SQuxxt

http://rec-law.us/1RYUVnJ

22

2/22/16

NY

Gore Mountain Ski Center

 

Double Black Diamond

struck several trees

 

 

65

M

Minerva, NY

Y

http://rec-law.us/1p1jSDG

http://rec-law.us/1VCcFnT

23

2/25

CO

Beaver Creek

 

Intermediate

 

 

 

39

M

Knoxville, TN

 

http://rec-law.us/1QdvDQj

http://rec-law.us/1OFH6UP

24

2/26

MI

Crystal Mountain

Cheers Race Course

Intermediate

Lost control & slid backward

 

 

58

M

Traverse City, MI

Y

http://rec-law.us/1QdvDQj

http://rec-law.us/1n8gDJ7

25

2/27

PA

Seven Springs

Wagner Trail

 

Skier v. Skier Collision

 

 

51

M

Delmont

 

http://rec-law.us/1RA8V5e

http://rec-law.us/1LPZcnc

26

2/27

 

Squaw Valley resort

Headwall

 

fell and slid down the slope through a stand of trees, suffering multiple injuries

 

 

62

F

Olympic Valley

Y

http://rec-law.us/1Qh8MDD

http://rec-law.us/1Qh8MDD

Download a PDF of this Chart Here: 2015 – 2016 Ski Season Deaths 3.2.16

Our condolences go to the families of the deceased. Our thoughts extend to the families and staff at the ski areas who have to deal with these tragedies.

If you cannot read the entire chart you can download it here.

What do you think? Leave a comment.

If you like this let your friends know or post it on FB, Twitter or LinkedIn

Copyright 2015 Recreation Law (720) Edit Law

Email: Rec-law@recreation-law.com

Google+: +Recreation

Twitter: RecreationLaw

Facebook: Rec.Law.Now

Facebook Page: Outdoor Recreation & Adventure Travel Law

Blog: www.recreation-law.com

Mobile Site: http://m.recreation-law.com

#AdventureTourism, #AdventureTravelLaw, #AdventureTravelLawyer, #AttorneyatLaw, #Backpacking, #BicyclingLaw, #Camps, #ChallengeCourse, #ChallengeCourseLaw, #ChallengeCourseLawyer, #CyclingLaw, #FitnessLaw, #FitnessLawyer, #Hiking, #HumanPowered, #HumanPoweredRecreation, #IceClimbing, #JamesHMoss, #JimMoss, #Law, #Mountaineering, #Negligence, #OutdoorLaw, #OutdoorRecreationLaw, #OutsideLaw, #OutsideLawyer, #RecLaw, #Rec-Law, #RecLawBlog, #Rec-LawBlog, #RecLawyer, #RecreationalLawyer, #RecreationLaw, #RecreationLawBlog, #RecreationLawcom, #Recreation-Lawcom, #Recreation-Law.com, #RiskManagement, #RockClimbing, #RockClimbingLawyer, #RopesCourse, #RopesCourseLawyer, #SkiAreas, #Skiing, #SkiLaw, #Snowboarding, #SummerCamp, #Tourism, #TravelLaw, #YouthCamps, #ZipLineLawyer, Skiing, Snowboarding, Fatality, Ski Area, Tubing, Chair Lift,  Jackson Hole, Steamboat Springs Ski Resort, Snoqualmie Pass, Mount Snow, Park City, Vail, Bear Valley, Whiteface, Snoqualmie Pass, Burke Mountain Ski Area, Park City Mtn Resort, Cascade Mountain Ski Hill, Mt. Waterman, Blue Mountain Ski Area, Solider Mountain, Solider Mountain, Winter Park, Aspen, Snowbasin, Heavenly Mountain, Burke Mountain, Park City, Cascade Mountain, Blue Mountain, Mt. Waterman, Squaw Valley resort,

 


2015-2016 In bound ski/board fatalities

This list is not guaranteed to be accurate. The information is found from web searches and news dispatches. Those references are part of the chart. If you have a source for information on any fatality please leave a comment or contact me. Thank you.

If this information is incorrect or incomplete please let me know.  This is up to date as of January 15, 2016. Thanks.

Skiing and Snowboarding are still safer than being in your kitchen or bathroom. This information is not to scare you away from skiing but to help you understand the risks.

Red type is natural or medical conditions that occurred inbounds on the slopes

Green Type is Fatalities while sledding at the Resort

Blue Type is a Lift Accidents

2015 – 2016 Ski Season Fatalities

#

Date

State

Resort

Where

Trail Difficulty

How

Cause

Ski/ Board

Age

Sex

Home town

Helmet

Reference

Ref # 2

1

11/29

CA

Bear Mountain

 

 

she collided with a metal stairway[i]

 

Ski

21

F

Jackson Township, CA

 

http://rec-law.us/1HAkwAp

http://rec-law.us/1LJ13sm

2

12/7

WY

Jackson Hole

Moran Run

Blue

Hit tree

 

Board

23

F

Boston, MA

Y

http://rec-law.us/1OO1M1P

http://rec-law.us/1NGuZLh

3

12/15

CO

Steamboat

 

 

fell, landing face down in the snow

 

Ski

70

M

Louisville, CO

 

http://rec-law.us/1TPTaHk

http://rec-law.us/1YksmR0

4

12/19

WA

Snoqualmie Pass

Silver Fir

 

tree-well

 

Ski

50

M

North Bend, WA

 

http://rec-law.us/1ZDDJG7

http://rec-law.us/1ms5yCF

5

12/22

WY

Jackson Hole

Sundance run

 

found inverted in a tree well

 

Ski

25

F

Jackson Hole, WY

Y

http://rec-law.us/1kwuRlK

http://rec-law.us/1mlDKjR

6

12/23

NY

Whiteface Lake Placid

Summit Express

Blue

fell and struck his head

blunt impact to the head

Board

26

M

Litiz, PA

N

http://rec-law.us/1P2BrJ2

 

7

12/23

CA

Bear Valley

 

 

 

 

Ski

71

M

 

 

http://rec-law.us/1JMVglS

http://rec-law.us/1OvzGUe

8

1/6

CO

Vail

 

 

 

tree well

Board

25

M

Avon, CO

 

http://rec-law.us/1ZqNv1y

http://rec-law.us/1ZYSDa6

9

1/12

UT

Park City

 

Intermediate

 

 

 

60

M

 

 

http://rec-law.us/1SNa4bx

 

10

1/24

VT

Mount Snow

 

 

 

 

Board

56

M

Simsbury, CT

 

http://rec-law.us/20r061U

http://rec-law.us/20r061U

 

Our condolences go to the families of the deceased. Our thoughts extend to the families and staff at the ski areas who have to deal with these tragedies.

You can download a PDF of this chart here: 2015 – 2016 Ski Season Deaths 1.15.16.

What do you think? Leave a comment.

If you like this let your friends know or post it on FB,

Download a PDF of this chart here.

Our condolences go to the families of the deceased. Our thoughts extend to the families and staff at the ski areas who have to deal with these tragedies.

What do you think? Leave a comment.

If you like this let your friends know or post it on FB,

Twitter or LinkedIn

Copyright 2015 Recreation Law (720) Edit Law

Email: Rec-law@recreation-law.com

Google+: +Recreation

Twitter: RecreationLaw

Facebook: Rec.Law.Now

Facebook Page: Outdoor Recreation & Adventure Travel Law

Blog: www.recreation-law.com

Mobile Site: http://m.recreation-law.com

#AdventureTourism, #AdventureTravelLaw, #AdventureTravelLawyer, #AttorneyatLaw, #Backpacking, #BicyclingLaw, #Camps, #ChallengeCourse, #ChallengeCourseLaw, #ChallengeCourseLawyer, #CyclingLaw, #FitnessLaw, #FitnessLawyer, #Hiking, #HumanPowered, #HumanPoweredRecreation, #IceClimbing, #JamesHMoss, #JimMoss, #Law, #Mountaineering, #Negligence, #OutdoorLaw, #OutdoorRecreationLaw, #OutsideLaw, #OutsideLawyer, #RecLaw, #Rec-Law, #RecLawBlog, #Rec-LawBlog, #RecLawyer, #RecreationalLawyer, #RecreationLaw, #RecreationLawBlog, #RecreationLawcom, #Recreation-Lawcom, #Recreation-Law.com, #RiskManagement, #RockClimbing, #RockClimbingLawyer, #RopesCourse, #RopesCourseLawyer, #SkiAreas, #Skiing, #SkiLaw, #Snowboarding, #SummerCamp, #Tourism, #TravelLaw, #YouthCamps, #ZipLineLawyer, Skiing, Snowboarding, Fatality, Ski Area, Tubing, Breckenridge, Chair Lift, Hunter Mountain, Jackson Hole, Pine Knob, Eldora, Keystone, Breckenridge, Eldora, Keystone, Pine Knob, Jackson Hole, Hunter Mtn, Mt. Hood Skibowl, Snowbird Ski Resort, Nashoba Valley Ski Area, Northstar California ski resort, Arizona Snowbowl, Copper Mtn, Keystone Resort, Stowe Mountain Resort, Mission Ridge Ski, Crested Butte, Breckenridge, Mr. Bachelor, White Pass Ski Area, Deer Valley Ski Resort, Steamboat Springs Ski Resort, Snoqualmie Pass, Mount Snow, Park City, Vail,

 


 


2015-2016 In bound ski/board fatalities

This list is not guaranteed to be accurate. The information is found from web searches and news dispatches. Those references are part of the chart. If you have a source for information on any fatality please leave a comment or contact me. Thank you.

If this information is incorrect or incomplete please let me know.  This is up to date as of December 30, 2015. Thanks.

Skiing and Snowboarding are still safer than being in your kitchen or bathroom. This information is not to scare you away from skiing but to help you understand the risks.

Red type is natural or medical conditions that occurred inbounds on the slopes

Green Type is Fatalities while sledding at the Resort

Blue Type is a Lift Accidents

2015 – 2016 Ski Season Fatalities

#

Date

State

Resort

Where

Trail Difficulty

How

Cause

Ski/ Board

Age

Sex

Home town

Helmet

Reference

Ref # 2

1

11/29

CA

Bear Mountain

 

 

she collided with a metal stairway[i]

 

Ski

21

F

Jackson Township, CA

 

http://rec-law.us/1HAkwAp

http://rec-law.us/1LJ13sm

2

12/7

WY

Jackson Hole

Moran Run

Blue

Hit tree

 

Board

23

F

Boston, MA

Y

http://rec-law.us/1OO1M1P

http://rec-law.us/1NGuZLh

3

12/15

CO

Steamboat

 

 

fell, landing face down in the snow

 

Ski

70

M

Louisville, CO

 

http://rec-law.us/1TPTaHk

http://rec-law.us/1YksmR0

 

12/19

WA

Snoqualmie Pass

Silver Fir

 

tree-well

 

Ski

50

M

North Bend, WA

 

http://rec-law.us/1ZDDJG7

http://rec-law.us/1ms5yCF

 

12/22

WY

Jackson Hole

Sundance run

 

found inverted in a tree well

 

Ski

25

F

Jackson Hole, WY

Y

http://rec-law.us/1kwuRlK

http://rec-law.us/1mlDKjR

 

12/23

NY

Whiteface Lake Placid

Summit Express

Blue

fell and struck his head

blunt impact to the head

Board

26

M

Litiz, PA

N

http://rec-law.us/1P2BrJ2

 

 

Our condolences go to the families of the deceased. Our thoughts extend to the families and staff at the ski areas who have to deal with these tragedies.

If you are unable to view the entire table Email me at Jim@Rec-law.us and put Ski Area Fatality Chart in the subject line. I’ll reply with a PDF of the chart.

What do you think? Leave a comment.

If you like this let your friends know or post it on FB, Twitter or LinkedIn

Copyright 2015 Recreation Law (720) Edit Law

Email: Rec-law@recreation-law.com

Google+: +Recreation

Twitter: RecreationLaw

Facebook: Rec.Law.Now

Facebook Page: Outdoor Recreation & Adventure Travel Law

Blog: www.recreation-law.com

Mobile Site: http://m.recreation-law.com

#AdventureTourism, #AdventureTravelLaw, #AdventureTravelLawyer, #AttorneyatLaw, #Backpacking, #BicyclingLaw, #Camps, #ChallengeCourse, #ChallengeCourseLaw, #ChallengeCourseLawyer, #CyclingLaw, #FitnessLaw, #FitnessLawyer, #Hiking, #HumanPowered, #HumanPoweredRecreation, #IceClimbing, #JamesHMoss, #JimMoss, #Law, #Mountaineering, #Negligence, #OutdoorLaw, #OutdoorRecreationLaw, #OutsideLaw, #OutsideLawyer, #RecLaw, #Rec-Law, #RecLawBlog, #Rec-LawBlog, #RecLawyer, #RecreationalLawyer, #RecreationLaw, #RecreationLawBlog, #RecreationLawcom, #Recreation-Lawcom, #Recreation-Law.com, #RiskManagement, #RockClimbing, #RockClimbingLawyer, #RopesCourse, #RopesCourseLawyer, #SkiAreas, #Skiing, #SkiLaw, #Snowboarding, #SummerCamp, #Tourism, #TravelLaw, #YouthCamps, #ZipLineLawyer, Skiing, Snowboarding, Fatality, Ski Area, Tubing, Breckenridge, Chair Lift, Hunter Mountain, Jackson Hole, Pine Knob, Eldora, Keystone, Breckenridge, Eldora, Keystone, Pine Knob, Jackson Hole, Hunter Mtn, Mt. Hood Skibowl, Snowbird Ski Resort, Nashoba Valley Ski Area, Northstar California ski resort, Arizona Snowbowl, Copper Mtn, Keystone Resort, Stowe Mountain Resort, Mission Ridge Ski, Crested Butte, Breckenridge, Mr. Bachelor, White Pass Ski Area, Deer Valley Ski Resort, Steamboat Springs Ski Resort, Snoqualmie Pass

 


[i] the staircase was at the end of a ski trail and led to a patio area.