Pryor v. Iberia Parish School Board
2011 La. LEXIS 610
La.2011Background
- Pryor, 69, attending a high school football game at Lloyd G. Porter Stadium owned by Iberia Parish School Board.
- East-side visitors’ seating is a metal- frame bleacher; west-side is wooden seating with ramps and handicap seating.
- Pryor ascended the east-side bleachers; she noted an unusually high first seat board and had to be assisted.
- At halftime she descended the bleachers, then fell when stepping down the 18-inch gap between the first and second rows.
- Plaintiff sued the school board alleging defective bleachers; the district court dismissed with prejudice after a risk/utility analysis.
- The court of appeal reversed and allocated fault 70% to the school board and 30% to Pryor; certiorari granted to review whether the bleachers were unreasonably dangerous; the Supreme Court reinstated the district court’s judgment and dismissed fault/damages analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the bleachers’ design/unreasonably dangerous? | Pryor: the 18-inch gap is open and obvious and yields no social utility. | School Board: social utility outweighs risk; the gap is part of design and not inherently dangerous. | Bleachers not unreasonably dangerous; district court ruling affirmed. |
| Does risk-utility balance support removal of liability here? | Pryor’s fault should not override danger posed by the gap given her impairment. | Board: social utility and feasibility of repair counterbalance risk; plaintiff knew of the gap. | Risk-utility balance favors no duty to warn or repair beyond existing social utility. |
| Was the court obligated to consider social utility of the bleachers as a whole? | The entire bleacher system bears potential social value. | The design feature (18-inch gap) is part of the bleachers’ function. | Bleachers’ overall social utility outweighs the minimal risk from the gap. |
| Did the plaintiff’s awareness of the risk affect liability? | Pryor was aware of the 18-inch gap. | Open and obvious risks may negate duty to protect. | Pryor’s knowledge does not create liability; risk deemed open and obvious. |
Key Cases Cited
- Reed v. Wal-Mart, Inc., 708 So.2d 362 (La. 1998) (balance risk and social utility; open/obvious hazards subject to reasonableness)
- Pitre v. Louisiana Tech University, 673 So.2d 585 (La. 1996) (risk-utility framework for premises liability)
- Entrevia v. Hood, 427 So.2d 1146 (La. 1983) (premises liability balancing factors)
- Langlois v. Allied Chemical Corp., 249 So.2d 133 (La. 1971) (utility of the thing and risk assessment in duty analysis)
- Boyle v. Board of Supervisors, 685 So.2d 1080 (La. 1997) (risk-utility approach to determine unreasonableness of danger)
- Eisenhardt v. Snook, 8 So.3d 541 (La. 2009) (open and obvious hazards; duty considerations)
- Dauzat v. Curnest Guillot Logging, Inc., 995 So.2d 1184 (La. 2008) (utility analysis of risks in inherently dangerous activities)