Williams v. Univ. of Akron
2016 Ohio 7209
| Ohio Ct. Cl. | 2016Background
- Raymond Williams alleged a JAR Arena seat collapsed beneath him during a University of Akron (UA) men’s basketball game on November 16, 2015, injuring his lower back, right hip, and right knee.
- Williams claimed $5,265 in medical bills and sought $10,000 total for medical expenses and pain and suffering; he had no insurance for the injury.
- UA employees (an usher and Manager of Operations and Events Elizabeth Pannucci) responded; Williams said the seat bottom dropped but he caught himself on the armrests, declined medical treatment and did not complete an incident report; UA staff completed one per protocol.
- UA’s investigation showed Williams held a general-admission bleacher ticket, not the reserved seat he attempted to use.
- UA submitted affidavits and evidence that it conducts routine external inspections (most recently June 11, 2015) and regular visual checks before events; no notice of seat defects was shown.
- The court found Williams failed to prove UA breached its duty of ordinary care or that any breach caused his injuries and denied the claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether UA breached duty of ordinary care to an invitee by failing to maintain safe seating | Williams: the seat broke under him causing injury | UA: conducted regular inspections, had no notice of defects, and corrected issues when identified | Court: Williams failed to show UA breached its duty |
| Whether plaintiff proved causation between seat defect and injuries | Williams: seat collapse caused his back/hip/knee injuries | UA: no evidence of preexisting defect or notice; Williams declined treatment and did not report fall | Court: insufficient evidence that a defect caused the injuries |
| Whether UA had actual or constructive notice of seat defect | Williams: implied that UA should be responsible for seat failure | UA: routine external inspections and event visual checks showed no defects; no patron reports about that seat prior | Court: UA had no notice; plaintiff did not show UA should have known of defect |
| Whether plaintiff’s status/ticket affects duty or recovery | Williams: attended game as an invitee and seeks recovery | UA: plaintiff attempted to sit in reserved seat but held general-admission ticket (bleacher seating) | Court: treated plaintiff as an invitee but still found no breach or causation |
Key Cases Cited
- Mussivand v. David, 45 Ohio St.3d 314, 544 N.E.2d 265 (1989) (elements required to establish negligence)
- Jeffers v. Olexo, 43 Ohio St.3d 140, 539 N.E.2d 614 (1989) (absence of any negligence element defeats claim)
- Light v. Ohio Univ., 28 Ohio St.3d 66, 502 N.E.2d 611 (1986) (invitee status and owner’s duty to exercise ordinary care to maintain safe premises)
- Baldauf v. Kent State Univ., 49 Ohio App.3d 46, 550 N.E.2d 517 (10th Dist. 1988) (owner not insurer against all risks; duty balanced against risk exposure)