Arnold v. City of Cedar Rapids

In Arnold v. City of Cedar Rapids, 443 N.W.2d 332 (Iowa 1989) the Court stated: The principle seems well established that the owner or operator of a ballpark fully discharges any obligation to protect spectators from thrown or hit balls by providing seating in a fully protected area. Where a spectator rejects the protected seating and opts for seating that is not, or is less, protected the owner or operator is not liable. Arnold, 443 N.W.2d at 333. The supreme court set out a two-prong test in Arnold regarding the duty of a baseball park owner or operator to protect spectators: (1) the proprietor need only provide screening for the area of the field behind home plate where the danger of being struck by a ball is the greatest; and (2) such screening must be of sufficient extent to provide adequate protection for as many spectators as may reasonably be expected to desire such seating in the course of an ordinary game. Id. The court ultimately found in Arnold that because the defendants had screened the most dangerous parts of the spectator stands, behind home plate, and there was sufficient seating there for the plaintiff, the defendants owed Arnold nothing further. Id at 333-34.