## Facts

- Elliot Maddox, a professional baseball player, was injured on June 13, 1975, during a night game at Shea Stadium while playing center field.
- While attempting to stop after chasing a fly ball, Maddox’s left foot slid on a wet area and his right foot stuck in a mud puddle, causing a knee injury that required multiple surgeries and ended his career.
- Before the injury, Maddox observed that the outfield was very wet, muddy, and had standing water visible above the grass.
- Maddox knew a game the prior night had been canceled due to weather and poor field conditions, and he had experience playing on wet fields.
- During the game, Maddox called the “puddling” to the attention of groundskeepers and had previously commented to team/club personnel about wet field conditions.
- Maddox did not claim that he asked to be removed from the game or that he was compelled to continue playing.
- Maddox and his wife sued the City and other stadium-related entities, alleging negligent design, construction, or maintenance of the stadium drainage system created an unreasonably dangerous condition.

## Issues

1. Whether Maddox’s own testimony established, as a matter of law, that he knowingly and voluntarily assumed the risk of the wet and muddy field conditions that caused his injury.
2. Whether the alleged negligent field condition fell outside the scope of assumed risks in athletic participation.
3. Whether assumption of risk could be resolved on summary judgment rather than submitted to a jury on this record.

## Decision

- The Court of Appeals affirmed the Appellate Division’s order granting summary judgment to defendants and dismissing the complaints.
- The court held Maddox’s deposition testimony conclusively showed he was aware of the wet, muddy condition and the specific puddle involved, and he appreciated the associated risk.
- By continuing to play despite that knowledge and without showing compulsion to do so, Maddox assumed the risk as a matter of law.
- Because the claim accrued before New York’s comparative negligence statute took effect, assumption of risk (and contributory negligence) operated as a complete bar to recovery.

## Legal Principles

- A participant who has actual knowledge of a condition, appreciates the risk it poses, and voluntarily continues participation may be barred by implied assumption of risk.
- Although assumption of risk is often a jury question, summary judgment is proper when the plaintiff’s own admissions eliminate any material dispute regarding knowledge and voluntariness.
- In athletic-injury cases, the doctrine applies to professional athletes when the record shows knowing and voluntary exposure to the complained-of condition.
- For pre-comparative-negligence accruals, assumption of risk can function as a total defense rather than a basis for apportioning fault.

## Conclusion

The court concluded that Maddox’s admitted awareness of the wet, puddled outfield and his choice to continue playing established implied assumption of risk as a matter of law, requiring dismissal on summary judgment.


Maddox v. City of New York, 66 N.Y.2d 270 (N.Y. 1985)