Moser v. Ratinoff

In Moser v. Ratinoff (2003) 105 Cal.App.4th 1211, the plaintiff was injured during the "Death Valley Double Century," an organized, 200-mile, noncompetitive bicycle ride on public highways. Moser noted: "It is true that bicycle riding is a means of transportation-as is automobile driving. Normal automobile driving, which obviously is not an activity covered by the assumption of risk doctrine, requires skill, can be done for enjoyment, and entails risks of injury. But organized, long-distance bicycle rides on public highways with large numbers of riders involve physical exertion and athletic risks not generally associated with automobile driving or individual bicycle riding on public streets or on bicycle lanes or paths." (Id. at p. 1221.)