Seth Griffith v. Jumptime, Meridian
161 Idaho 913
| Idaho | 2017Background
- At age 17, Griffith attempted a triple front flip into a foam pit at JumpTime and suffered a cervical fracture requiring fusion of C6–C7.
- He had been using runway trampolines and foam pits for ~45 minutes, repeatedly performing double front flips into the small pit and landing on his back or buttocks.
- Facility posted multiple foam-pit signs instructing patrons to land feet-first; employee manual required attendants to follow and enforce wall rules.
- A JumpTime attendant observed Griffith and complimented a prior back flip but did not admonish him to land feet-first.
- Griffith sued for negligence, arguing JumpTime owed a supervisory duty to minors and that lack of admonishment caused him to attempt the triple flip.
- The district court granted summary judgment for JumpTime for lack of evidence of negligence and, crucially, lack of causal connection; Griffith appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether JumpTime breached a duty by failing to supervise/admonish and whether that caused Griffith's injury | Griffith: as a minor JumpTime had duty to supervise; attendant’s failure to enforce signage (to land feet-first) emboldened him to attempt the triple flip | JumpTime: industry standards permitted landing on feet, buttocks, or back; no evidence attendant knew or should have known Griffith would attempt a triple; no causal link | Court: No genuine issue of causation; Griffith’s testimony shows he decided to attempt the triple based on confidence from ease of doubles, not attendant conduct — summary judgment affirmed |
| Whether prevailing party is entitled to appellate attorney fees under Idaho Code § 12-121 | Griffith requested fees if prevailing | JumpTime requested fees as prevailing party | Court: denied Griffith fees; declined to award JumpTime fees on appeal (appeal not frivolous/unreasonable) |
Key Cases Cited
- Infanger v. City of Salmon, 137 Idaho 45 (discussing summary-judgment standard and construing facts for nonmoving party)
- Alegria v. Payonk, 101 Idaho 617 (elements of common-law negligence)
- McGrew v. McGrew, 139 Idaho 551 (standard for awarding appellate attorney fees under Idaho Code § 12-121)
- Benz v. D.L. Evans Bank, 152 Idaho 215 (further explanation of § 12-121 fee award standard)
- VanderWal v. Albar, Inc., 154 Idaho 816 (prevailing party rule under § 12-121)