Patton v. United States of America Rugby Football Union

Robert Carson Patton II (plaintiff) and his father, Donald Lee Patton, attended an amateur rugby tournament. Robert played in the tournament, and Donald was a spectator. It was a hot and muggy day; weather forecasts called for possible thunderstorms, and the National Weather Service issued a thunderstorm warning for the area. The rain had started by the outset of Robert’s match, and thunder could be heard in close temporal proximity to lightning flashes. Kevin Eager (defendant)—the referee for Robert’s match—did not stop the match even as the rain increased in intensity and lightning flashed directly over the field. After Robert’s match ended, Robert and Donald were struck by lightning as they tried to get to their car. Donald was killed, and Robert was seriously injured. Robert and several family members (collectively, Pattons) (plaintiffs) sued the America Rugby Football Union, Ltd., d/b/a USA Rugby (USA Rugby) (defendant), which organized the tournament, as well as the referee and related organizations (collectively, defendants) for negligence. USA Rugby and Eager made a motion to dismiss the complaint, which the trial court granted. The Pattons appealed, arguing that Robert and Donald had a special relationship with USA Rugby and Eager, pursuant to which USA Rugby and Eager had a duty—which they breached—to protect Robert and Donald. Per the Pattons, participants in a sporting event trust that the event’s organizers will protect their safety. The Pattons also argued that it was reasonably foreseeable to USA Rugby and Eager that Robert would not stop playing if the match was not suspended and that Donald would not abandon Robert while he was playing. USA Rugby and Eager denied the existence of a special relationship with Robert or Donald. USA Rugby and Eager further asserted that they had no control over Robert or Donald’s conduct and that Robert and Donald were not dependent on and did not rely on USA Rugby or Eager.