Codd v. Stevens Pass, Inc
In Codd v. Stevens Pass, Inc., 45 Wn. App. 393, 725 P.2d 1008, 1010 (Wash. Ct. App. 1986), the decedent caught his ski tips on a mogul and plummeted head first into another mogul, likely hitting his head on a snow covered rock.
The appellant maintained the ski operator negligently warned the decedent when it sectioned off a jump downhill from the accident site because the warning gave skiers the impression the accident area had been inspected for hazards.
The Washington Court of Appeals found a triable issue of fact and stated:
"One who attempts, albeit gratuitously, to warn a person in danger must do so with reasonable care. If his failure to exercise such care results in an increased risk of harm, he is liable for any physical damage which the reliance causes." 725 P.2d at 1014.