Angland v. Mountain Creek Resort, Inc., 213 N.J. 573

Angland died after a collision with Brownlee on a Mountain Creek slope; Angland was skiing and Brownlee snowboarding on the same trail.
Angland collided near a concrete bridge; skull fracture led to death days later.
Ski Act applies to ski area operators and skiers; question is whether it also governs skier–skier claims.
Brownlee argues Ski Act does not apply to claims between skiers, advocating the common-law recklessness standard.
Plaintiffs contend Ski Act governs skier–skier claims or, failing that, recklessness applies but there are genuine issues for trial.
Trial and appellate courts held the Ski Act applies to ski-area–vs–skier claims and pre-empts common law; court granted review on scope of Ski Act and standard of care.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the Ski Act apply to claims between skiers?	Ski Act governs duties of skiers; applies to all skiing participants.	Ski Act does not cover skier–skier claims; only operator–skiers claims.	Ski Act does not govern claims between skiers.
What standard governs a skier’s liability to another participant when Ski Act does not apply?	Common-law recklessness standard applies; record shows possible recklessness.	Recklessness standard should apply; no evidence of recklessness.	Common-law recklessness standard applies to skier–skier claims; trial court's remand for trial.

Crawn v. Campo, 136 N.J. 494 (1994) (recklessness standard for participation in recreational activities)
Brett v. Great American Recreation, 144 N.J. 479 (1996) ( Ski Act scope; pre-emption relating to operators vs. skiers)
Schick v. Ferolito, 167 N.J. 7 (2001) (recklessness standard in recreational sports generally)
Meistrich v. Casino Arena Attractions, Inc., 31 N.J. 44 (1959) (assumed risk concepts shaping duty and recovery in sports contexts)
Stelluti v. Casapenn Enters., 203 N.J. 286 (2010) (recklessness and assumption of risk in health-club context; relevance to sports)