Galan v. Covenant House New Orleans

In Galan v. Covenant House New Orleans (La.Ct.App. 1997) 695 So.2d 1007, after a haunted house patron walked through a fake "exit," a chainsaw carrying actor jumped out to frighten the patrons "one last time." (Id. at p. 1007.) The plaintiff sued alleging the defendants breached their duty "by placing their last exhibit outside of the exit ... at a point where patrons would no longer expect to be frightened." (Id. at p. 1008.) The Galan court rejected the argument, concluding: "Patrons in a Halloween haunted house are expected to be surprised, startled and scared by the exhibits but the operator does not have a duty to guard against patrons reacting in bizarre, frightened and unpredictable ways." (Id. at p. 1009.)