Beckwith v. Weber
2012 WY 62
| Wyo. | 2012Background
- Consolidated appeals stem from a judgment after a jury verdict in Beckwith v. Weber regarding injuries from a horse fall during Gros Ventre River Ranch trail rides in Grand Teton National Park.
- Jury found Beckwith’s injuries resulted from an inherent risk of horseback riding under the Wyoming Recreation Safety Act, yielding no damages.
- Beckwith challenged the district court’s refusal to instruct on a contract-based duty of care and on whether the defendants provided skilled guides.
- Beckwith also challenged instructions on the meaning of terms defining inherent risk and on strict construction of exculpatory clauses.
- The case proceeded to trial in 2010; Beckwith sought to frame negligence as non-inherent risks and sought a verdict form addressing guide skill and duties; the district court used an inherent-risk-first verdict form.
- Costs were later awarded to the appellees, and Beckwith appealed that ruling in S-11-0245.]
- Note: The summary includes only legally material, core facts germane to the issues, arguments, and disposition.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Duty of care sources under the Act | Beckwith argues contract-based duty via risk acknowledgment creates a duty apart from inherent risks. | Weber/WV contend duty, if any, arises from law, not contract, and the form does not remove inherent-risk scope. | District court did not err; duty sources not for jury; contract language cannot remove inherent-risk scope. |
| Meaning of inherent risk terms | Beckwith seeks definitions of 'characteristic,' 'intrinsic,' and 'integral' to clarify inherent risk. | Statutory terms have ordinary meanings; no need for further definition. | Court declined to give extra definitions; terms have plain meaning under Masias/Ewing framework. |
| Exculpatory clause construed | Exculpatory clause should be strictly construed beyond inherent-risk scope. | Clause limited to inherent risks; trial court construed narrowly; no reversible error. | No error; exculpatory clause not misapplied beyond inherent-risk scope; instruction adequate. |
| Presumption of due care | Beckwith sought instruction that she was presumed to exercise due care. | No basis to presume due care in an ongoing living plaintiff with eyewitnesses; defense abandoned contributory fault. | Instruction not error; verdict rested on inherent-risk finding; not outcome-determinative. |
| Award of costs | Beckwith contends cost denial or reduction due to indigence and financial disparity. | District court properly weighed financials and evidence; reduction not an abuse of discretion. | District court did not abuse discretion; costs awarded were reasonable under the circumstances. |
Key Cases Cited
- Masias v. State, 233 P.3d 944 (Wy. 2010) (court declines extrinsic definitions for inherent-risk terms; plain meaning suffices)
- Ewing v. State, 157 P.3d 943 (Wy. 2007) (clarifies statutory interpretation of inherent risk terms)
- Jackson Hole Mtn. Resort Corp. v. Rohrman, 150 P.3d 167 (Wy. 2006) (inherent-risk question generally for jury; summary-judgment when undisputed)
- Addakai v. Witt, 31 P.3d 70 (Wy. 2001) (standard for reviewing jury instructions; abuse of discretion analysis)
- DeJulio v. Foster, 715 P.2d 182 (Wy. 1986) (due-care instruction not required; determinations at issue)