Jones v. Three Rivers Mgmt. Corp

In Jones v. Three Rivers Mgmt. Corp. (1978), 483 Pa. 75, 394 A.2d 546, a ballpark patron who was hit in the eye by a ball during batting practice while he was standing in an interior walkway in the stadium's outer concourse filed a negligence action against the ballpark. Id. at 551-552, 394 A.2d 546. Although Jones was a case of first impression in Pennsylvania involving a baseball stadium's liability for damages incurred by a patron who was struck by a batted ball, the Court acknowledged the well-settled principle that a ballpark patron knowingly accepts the reasonable risks inherent in and incident to the game. Id. at 549, n. 5, 394 A.2d 546. However, contrary to the general rule, the Court concluded that the owner of the ballpark had a duty to protect its patrons due to the specific architectural features of the stadium. The Court's decision was based upon open archways that forced fans to use unprotected areas to arrive at the game, which the Court concluded were unique, created a risk that was not an inherent feature of the spectator sport of baseball, and were not compelled by or associated with the manner in which baseball is usually played or viewed. Id. at 551-552, 394 A.2d 546.