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5 Berkeley J. Ent. & Sports L. 1 (2016)

handle is hein.journals/bjesl5 and id is 1 raw text is: Potential Stadium Owner Liability for Outdoor Ice Hockey Games Joshua D. Winneker' I. In tro d u ctio n ...................................................................................................... 1 II. History and Current Status of Outdoor Ice Hockey Games ....................... 2 III. Prem ises L iability .................................................................................... . . 4 IV. Current Legal Theories for Sport Stadium Owner Liability ..................... 6 A . Baseball's Lim ited Duty Rule ...................................................... 6 B . The N o D uty R ule .................................................................... 8 C. Negligence and Comparative Negligence .................................... 9 V. Indoor Ice Hockey Stadium Owner Liability ........................................... 10 VI. Outdoor Ice Hockey Stadium Liability .................................................... 13 V II. C on clu sion ........................................................................................... . . 15 I. INTRODUCTION Despite their relative novelty in the United States, outdoor ice hockey 2 games are occurring more frequently and becoming more popular. Since 2008, the National Hockey League (NHL) has hosted its Winter Classic, 3 where two teams compete on an outdoor rink. The rinks are typically set up inside a football or baseball stadium, creating a unique and exciting atmos- phere.4 Because of these uniquely exciting events, the NHL has recorded its highest attendance levels at these games. To date, Winter Classic games have featured a number of teams from across the country, including the Boston Bruins, Philadelphia Flyers, Los Angeles Kings, and the Anaheim Ducks, to name a few.5 1. Joshua D. Winneker, JD, Assistant Professor, Misericordia University. I would like to thank Philip Schultze, Brooklyn Law School JD Candidate for his invaluable contributions, in- sight and research assistance. I would also like to thank Sara Leprowse, JD, for her research assis- tance. 2. See Joshua D. Winneker, Potential Liability for Outdoor Collegiate Ice Hockey Games, COLL. SPORTS BuS. NEwS (Sep. 12, 2011), http://collegesportsbusinessnews.com/issue/october- 2011 /article/potential-liability -for-outdoor-collegiate-ice-hockey -games. 3. Id. 4. See infra, note 16. 5. Ken Gurnick, Fans pack into Dodger Stadium for outdoor ice hockey, MLB.COM (Jan.

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