Santopietro v. City of New Haven

In October 1988, Raymond Santopietro Jr. (plaintiff) attended an amateur softball game in a New Haven, Connecticut (defendant), park, which he observed from behind the backstop. Mark Piombino (defendant) played in the game. Piombino flung his bat toward the backstop. Piombino’s bat somehow went through the backstop and hit Santopietro, causing serious injuries. The game was umpired by David Brennan and Bruce Shepard (umpires) (defendants). The umpires were experienced umpires; they had received extensive training and had been certified by a national association of amateur umpires. Santopietro sued the umpires, alleging that the umpires had been negligent by not taking action in response to unruly behavior by Piombino’s teammates before Santopietro’s injury. Specifically, Santopietro alleged that Piombino’s teammates, among other things, engaged in taunting, used vulgar language, threw their gloves, kicked the dirt, and, in one case, threw a bat (bat incident). The umpires denied being aware of any misconduct by Piombino’s teammates. Moreover, Shepard testified that he would have ejected any player he saw throwing a bat. The umpires further testified that they had a duty to maintain control of the game to protect spectators, including by issuing warnings to players, but that whether to impose discipline in any specific instance was committed to their discretion. The district court issued a directed verdict in favor of the umpires, ruling that Santopietro failed to establish that the umpires violated the relevant standard of care. Santopietro appealed, arguing that the umpires’ own testimonies established the standard of care that the umpires allegedly failed to meet and that Santopietro presented sufficient evidence that the umpires did not meet that standard of care with respect to the alleged bat incident and taunting.