SW Legal studies in Business

Weightlifter Assumes Risk of Injury

Appeals court held that a powerlifter assumed the risk of injury and could not sue the lift meet organizers for not providing more training for spotters. Assumption of the risk bars negligence claims; only a claim of intentional or reckless behavior could proceed.

Topic Torts
Key Words

Negligence; Assumption of Risk; Weightlifting

C A S E   S U M M A R Y

Cotillo, a powerlifter with ten years experience, was injured during a competition when he attempted to lift 530 pounds at a meet sanctioned by the American Powerlifting Association (APA). Lifters could either use spotters they selected or could use spotters provided by the meet organizers. Cotillo used the spotters provided, who were high school students who had weightlifting experience. The spotters were in proper position but could not move quickly enough to stop Cotillo from dropping the weight and shattering his jaw. He sued the meet organizer and the APA for not properly training the spotters. The trial court dismissed the suit. Cotillo appealed. The court of special appeals reversed. Defendants appealed.


Reversed. Cotillo assumed the risk that spotters might negligently fail to catch the lift bar when he participated in the competition. He had knowledge of the risk, he appreciated the risk, and he voluntarily confronted the risk or danger. Assumption of risk completely bars recovery in a negligence suit. The danger here was foreseeable and an integral part of the sport. The alleged negligent training of the spotters was irrelevant to the assumption of risk. Any alleged improper training of the spotters did not pose an enhanced risk to Cotillo in the absence of evidence of intentional or reckless conduct.


American Powerlifting Association v. Cotillo, 934 A.2d 27 (Ct. App., Mary., 2007)

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