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Understanding Recreational Use Statues

This resource is offered for educational purposes only. It does not constitute legal advice.

As the popularity of mountain biking increases, so does the fear of lawsuits.  Landowners, trail builders, stewardship organizations, and even individual volunteers maintaining trails are concerned about being sued.  Internet forums are rife with examples of suits brought by injured trail users, leaving landowners concerned if it is worth the risk to allow mountain biking on their property.

Protection from liability can come from recreational use statutes, volunteer immunity acts, government tort liability acts, and even Adopt-a-Trail programs. Because these statutes and the case law that applies them are created are done on a state-by-state basis it’s difficult to provide a general rule that applies to all states.  The main purpose of this article is to look at how different state courts are interpreting Recreational Use Statutes (RUS) and what that could mean to landowners and trail maintenance organizations in particular.

What is a Recreational Use Statute?

Historically, RUS were enacted to encourage private landowners to make their land available for recreational activities such as hunting, fishing, and hiking by making it less likely that a property owner would be liable for damages to an injured recreational user.  The intent of RUS was to promote public recreational use of privately owned land but in some cases municipalities and public entities qualify as owners under their state RUS, allowing public land to fall within the protection of the RUS.  All states have a RUS and while the language varies, they generally provide that a landowner does not owe any recreational user a duty of care to keep their property safe for use, a duty to warn of dangerous conditions, or an assurance of the user’s safety.  However, the protection provided by the RUS can be lost if the landowner charges a fee for the use of the land or if the landowner is guilty of malicious conduct.

How does it work?

The basics of all RUS involve a landowner making their land available to the public for recreational purposes in exchange for immunity from liability. While RUS provides immunity to the landowner from liability, it does not protect the landowner from being sued for personal injury or wrongful death. The court will determine if the RUS applies to the facts of the case. 

If the RUS does not apply, then liability will be determined in accordance with principles of state law. If the RUS does apply, then the landowner is protected by the statute unless the landowner’s actions fall within those that are excluded such as maliciously or intentionally creating a hazard or charging a fee for use of the property..

How does the court determine if a RUS applies?

RUS vary by state, likewise the judicial interpretations of these RUS differ greatly.  Interpretation of critical terms in the RUS such as the landowner, land, recreation, and use, vary significantly from state to state and often yield different results.  In some situations, RUS protection has been expanded, for example, to include public managed lands like state parks.  The following will examine these key terms from a historical perspective, how courts have applied them, and how these interpretations affect IMBA chapters.

This is not a comprehensive analysis—if you need legal advice please consult a local attorney!


Who is a Landowner?

In order to be protected under a RUS, a person must qualify as an “owner.” Most statutes broadly define “owner” as owner of land, tenant, lessee, occupant or person in control of the premises.  Deeds, property agreements, and titles help to determine ownership but what constitutes control of premises and occupants?

The term “control of premises” is considered by several states. For instance, in Idaho, to be considered an “owner”, one must have authority to exclude the public. A snowmobiler was fatally injured while snowmobiling on a groomed trail within a National Forest in Fremont County, Idaho.  Fremont County had entered into a Cost-Share agreement with the Forest Service with the County responsible for grooming the trails. . The Court concluded that Fremont County was not entitled to immunity under the Idaho RUS as the County did not have the authority to grant or deny access to the snowmobile trails, only the Forest Service had that authority.   A Kentucky court addressed the meaning of “in control of premises” when it determined that school principals and maintenance workers  were “owners” of a school swingset.  Although they did not own the swingset, they were determined to be “owners” because of they had the duty to maintain school grounds.

  • By adopting a broad definition of "owner" and including the provision "in control of the premises" in KRS 411.190(1)(b), we believe the legislature intended to eliminate negligence liability, under the circumstances set forth in the statute, by removing the duty of care from individuals who have sufficient control to render them liable absent the statute's application.

A common question is whether RUS apply to agency managed lands such as BLM, DNR, and state parks. A few states specifically include public entities in the definition of owner including Indiana, Missouri, and Washington, while Iowa specifically excludes government entities.  South Carolina’s RUS applies to owner of land leased to the State or other subdivision.  Tennessee courts have determined that the RUS may apply to state parks and wildlife management areas. The majority of states do not specify either way and leave it to the courts to decide.  

Could IMBA Chapters be considered owners?

Whether a Chapter is considered a landowner depends on the state RUS definition of “owner” and outcomes based on former cases. North Carolina’s RUS specifically includes “any person who without compensation has constructed or maintained trails or other improvements  pursuant to a written agreement with any owner.” This means that  a volunteer is included in the definition of owner, and would likely be given the same immunity as other owners.  In Maine, “occupants” is defined as an individual, corporation, partnership, association or other legal entity that constructs or maintains trails or other improvements.  In Oregon, owner is defined as “possessor of any land interest including in possession of land”.  An Oregon court further expanded this definition to include a person maintaining and operating improvements on the lands is an “owner”.  In this case, two people drowned while swimming below a fish migration dam maintained by several entities including the Oregon Department of Fish & Wildlife and a municipality.  The court reasoned:

  • If those who merely construct improvements on the land qualify as owners, certainly those who maintain and operate improvements on land also fall within the scope of that definition.

States with a strong snowmobiling presence may be of help in analyzing whether a trail organization could qualify as an owner.  For instance, in Minnesota an injured snowmobiler sued a non-profit trail association. The Minnesota supreme court determined that a trail user organization that contracts with local government to acquire, construct and maintain trail is immune under the Municipal Tort Liability Act §466.03 and is also an “owner” and entitled to immunity under recreational use statute. Likewise, in a Wisconsin case, an injury suit was brought against a snowmobile club for leaving a grooming sled on the trail. The plaintiff’s negligence action was excluded as it related to maintenance of trail. The court noted that the club did regular maintenance and therefore was more than a transient presence.  However, a contrary conclusion was reached in New York, where a snowmobile club that marked trails on public land did not meet definition of “occupancy” and the RUS was not relevant.

What type of property is considered land?

Initially the intent of RUS was to limit the liability of private landowners in rural settings but over time, the definition of land has expanded to include buildings, structures, and equipment. Kansas courts have consistently determined that sledding hills, school grounds, and public pools are considered land for immunity purposes.  On the other hand, Pennsylvania’s RUS is not intended to provide immunity to  improved recreational facilities. In a case involving a historic site, which was mainly unimproved land, the court determined that it’s RUS did not apply as the site included restaurants, gift shop, and amphitheater. The more developed the property, the less likely it is to receive protection under the RUS.

Another important distinction is that the land must be open to the public for a RUS to apply.  In one Florida case, suit was brought against a water management company when a dirt biker ran into a drainage ditch that ran between a canal and road and was injured. In order to determine whether the RUS protected the water district from liability, the Florida Court of Appeals looked at whether a district provides the public with a park area or other land for outdoor recreational purposes or allows access over district lands for recreational purposes.  The water district stated that the land is open to the public. However, there was a “no trespassing” sign on the property. Since it wasn’t a clear issue, summary judgment for the district was denied and the plaintiff was ultimately awarded $4.2 million in damages.

Are bike trails considered land?

Only a few states, including Alaska and Arizona, include “trail” in the definition of land.  Most states include a broad definition to include both unimproved and improved land.  As improved land includes buildings and structures, it would seem that in most cases a dirt path or mountain bike trail would meet the definition of “land”.

However, the treatment of paved trails varies by state.  Immunity was granted to the landowner in a case in which a 7-year-old broke his leg while bicycling on a paved trail. An Arizona court determined that an urban path did not fit definition of “premise” under RUS statute.   Likewise an Illinois court ruled immunity applies only to “riding trails” that were unimproved, not to paved bike paths.

Whether a dirt trail that has man-made features is considered “improved” has yet to be determined. 

What about bike parks?

Unfortunately there is no clear cut answer.  Whether a RUS would apply depends on the particular state RUS definition of land and who owns the land.  There may be other state statutes that may apply.  If the bike park is owned by a government entity, then other legislation may apply (see tort liability section). In North Carolina, the expressed legislative purpose of the "Hazardous Recreation Parks Safety and Liability" statute is to encourage governmental owners or lessees of property to make land available to a governmental entity for skateboarding, inline skating, or freestyle bicycling without fearing liability:

  • It is recognized that governmental owners or lessees of property have failed to make property available for such activities because of the exposure to liability from lawsuits and the prohibitive cost of insurance, if insurance can be obtained for such activities. It is also recognized that risks and dangers are inherent in these activities, which risks and dangers should be assumed by those participating in the activities.

What is considered recreational use?

A mountain biker is injured while riding on a trail.  A classic example of a recreational use...but is it?

Many RUS specifically define “recreational use” or “recreational purpose” by listing activities such as hiking, swimming, fishing, etc.  Nineteen states specify “bicycling” while only Nevada, Texas, Utah, and Wyoming specify “mountain biking” as a recreational use. Other definitions include a “one who rides” (Arizona), “riding” (California), or “passage over and presence on land” (Iowa).

Instead of stated activities, some states take a broader approach utilizing terms such as “recreational pursuit” and “any outdoor activity.”  A Connecticut court poetically described recreational activities as those that “naturally arise from the desire and preferences of the person who is enticed away from the troubles and toil of the workaday world and who is drawn to the outdoors to partake of an activity that is pleasant for its own sake”.

Generally, courts will look at whether the activity is considered recreation by looking at several factors, including the legislative intent of the statute. In Wisconsin, the supreme court ruled that “a court give primary consideration to the nature and purpose of the activity without being controlled by the property user's subjective intent. Such a requirement comports with the focus of the statute which is the user's activity rather than the user's state of mind. The test also furthers the goal of the recreational immunity statute: it encourages landowners to open their land by according them a degree of certainty regarding their potential liability for injuries occurring on their land.”

Not all states focus on the recreational nature of the specific activity. In Louisiana, an injury does not have to arise out of recreational activity, just occur on property that is used for recreational purposes. In Rhode Island, the courts have held that “recreational use” is to be interpreted liberally and is not dependent on the user's specific activity at time of injury. For example, a person injured while returning to car after soccer game is considered using the property (park) for recreational use.

Based on this, it would seem logical that mountain biking is a recreational activity — but not so fast.

Recent trends show some courts are looking at whether riding a bike is a recreational use for purposes of the RUS or used as a means of transportation and therefore outside the protection of the RUS.  Consider these cases:

  • Hawaii:  Cyclist was injured on the Pearl Harbor bike path. The cyclist claimed he was commuting to work at the time he was injured and was not a recreational user.  The landowner argued that the path was made available to the public for recreational use. The court agreed with cyclist.

  • Massachusetts:  Summary judgment was upheld for the city based on  injuries to a cyclist on a path.  There, the appellate court ruled that the bicyclist’s subjective intent was irrelevant.  Since he entered the park on his bicycle, he was engaged in an objectively recreational activity and therefore the RUS applied.

  • New Jersey:  A touring cyclist was injured when he hit a pothole in a road, The plaintiff claimed that he passed through the recreational area simply as a means to get from point A to point B.  Court determined it wasn’t clear if the plaintiff was a recreational user or a “hybrid” user (a combination of transportation and recreation). Summary judgment was denied as there was an issue of material fact.

A 2015 decision in the state of Washington is particularly interesting in it’s determination of recreational use.  A cyclist riding on a paved path swerved to miss construction and struck a pole. The Washington Supreme Court honed in on issue of whether the trail was  for transportation with occasional recreational users or whether it was a recreational trail that was also used for transportation. The Court argued it was not enough for the City to show that the trail was open to bicycling, because “bicycling is not necessarily a recreational activity”, even though it is one of the recreational activities listed in the Washington RUS. The court noted that a key factor in it’s decision to deny immunity to the City is the intent of the landowner, not the intent of the user.  The Court is silent on the issue of how a landowner indicates their intent to make land available for recreational use.  Will landowners need to erect “for recreational use only” signs on their property?  

Immunity has its value, however, this case is also an example of the costs of litigation.  The injury occurred in 2006 and eight years later, the case was being sent back for trial.

The transportation versus recreation argument can create issues for landowners, particularly in urban settings.  Is a cyclist bicycling to get to their destination or enjoying a ride or a mix of the two?  


Landowners can lose RUS protection if they charge for the use of the land or if the actions of the landowner are determined to be willfully malicious conduct.

What constitutes a fee?

A primary way for landowners to lose immunity is to charge a fee for the use of the property.

But what constitutes a fee varies by state.

Many cases have centered on the issue of whether the landowner charged an entrance or parking fee.  These cases are rather straightforward.  If an entrance fee was charged, then the landowner lost immunity. However, there are few exceptions on whether a fee can be charged.  For example,  Nebraska allows charging a group rate without losing immunity while South Dakota allows non monetary gifts of up to $100.  Leasing fees paid by a state agency are allowed in almost half the states without losing RUS immunity. .

However, a 2009 case in Oregon has created some confusion about what could be considered a fee.  In that case, the Oregon supreme court determined in a 4-3 decision that a fee paid for a state park camping site constituted a “fee”, forfeiting immunity under the RUS even though the biking related injury occurred on a trail outside of the  camping area.  The park did not charge an entrance fee or a fee to use the park trails. The court determined that the camping fee was a fee “to go upon the land of the State.”  The dissenting opinion indicated that a charge imposed to use one portion of a parcel of land does not preclude recreational immunity from being applied to the other parcels of the land.  This case creates many unresolved questions.  Does a state park season pass constitute a “fee”?  Do landowners need to divide their land into fee and non-fee areas?

Could volunteer services be construed as a fee?

Volunteer trail organizations may be concerned that their services could be considered a fee, nullifying landowner protection.  Only a few states specify whether donated services constitute a fee. The Wisconsin RUS indicates payment does not include donation of services for management and conservation of the property resources. Likewise, in Vermont “consideration”  does not include any unpaid activity to protect and maintain the land for recreational use, which would appear to include volunteer trail maintenance.

What is malicious conduct?

Most RUS do not protect a landowner if they willfully, maliciously, or deliberately cause an injury.  Generally to be considered malicious the plaintiff must show that the landowner knew of the dangerous condition and willfully failed to guard recreational users or warn them about this dangerous condition.  Again, the different state courts differ in their interpretation of what constitutes malicious conduct.  In Vermont, to show willful/wanton misconduct, the act must be intentionally, designedly, knowingly or purposely, without justification or excuse.

Let’s look at how two similar factual situations, in this instance a cable strung across a path, can be interpreted differently by the courts.  In Illinois, a bicyclist struck a cable that was strung across a bike path in a state park. The cable was used to prevent cars from inadvertently driving down the bike path and was marked with reflective tape.  The plaintiff was unable to prove that the State acted in a willful and wanton manner or that it knew or failed to discover that its cable gates were reckless or careless.  The claim was denied and the motion to dismiss was allowed. However, in Tennessee, the plaintiff was driving his motorized dirt bike on a dirt path when he struck a cable that extended across the path approximately 8-12 inches above the ground.  The path was closed to motorized vehicles and signs along the path indicated such. The court determined that because reasonable minds could differ as to whether the State’s knowledge and conduct or lack of effective action amounted to gross negligence, summary judgment was deemed not appropriate.

What about assumption of risk—how does that fit in?

Natural surface trails present some inherent risk to all who use them.  Does this mean users need to be warned of every rock and root?

Most of the RUS specifically indicate that the landowner has no duty to  keep the  property safe, no duty to warn of dangerous conditions, and does not have to assure the safety of users. Arkansas’ RUS specifically states that landowners are not liable for injuries caused by natural or artificial conditions.  The Georgia RUS statute also provides that the owner does not extend any assurance that the premise is safe for any purpose. Texas also appears to put more responsibility on the injured party, where the andowner has no duty to protect or warn against dangerous conditions on land.  A landowner is not grossly negligent for failure to do so.

Some states evaluate whether the risk or danger is obvious. For example, in Illinois, a bicyclist, who was riding on a narrow hiking trail atop a cliff, fell and struck his head.  The court determined that generally a landowner has a duty to use reasonable care to keep the premises safe but that duty did not include a duty to warn invitees of obvious dangers or risks.

Utah is unusual in that it’s RUS addresses the inherent risks of activities with recreational purpose. It specifically indicates that one cannot make claim for personal injury caused by the inherent risks of participating in an activity including use of trails.  

Unlike Utah, most states do not specifically address the inherent risks in recreational activities but rather apply the Assumption of Risk doctrine.  Basically, Assumption of Risk is an affirmative defense in a negligence case in which the defendant claims that the situation was so inherently or obviously hazardous that the injured plaintiff would have or should have known there was danger and took the chance that he or she could be injured by proceeding anyway.

An Assumption of Risk defense was used successfully by the landowner in cases such as:

  • A mountain biker striking a tree root
  • A mountain biker fell when he hit a mound of sand at the bottom of a trail
  • A BMX biker jumping his bike off a dirt mound

In all three cases, the courts determined immunity applied for the landowner.

A few states indicate that the land user is responsible for being careful. Connecticut’s RUS specifies that the user is not relieved of exercising care in use of land. Similarly, in Idaho, the user is to exercise care in use of land and in their  activities.  

Montana limits liability in sport or recreational activity.  A person who participates in any sport or recreational activity assumes the inherent risk, whether known or unknown, and is responsible for all injury or death to the person and for all damage to the person’s property that resulted from the activity.  Furthermore, a provider is not required to eliminate, alter, or control inherent risks.

A California court held that rock climbers assume the risk that climbing anchors may give way and fail, “whether by one’s own slip or a co-climber’s stumble, is the very risk inherent in the sport of mountain climbing and cannot be completely eliminated without destroying the sport itself.”  Likewise, in a case involving a cheerleading injury, the court of appeals in California recognized the acrobatic, gymnastic nature of cheerleading, in particular noting that “whenever gravity is at play with the human body, the risk of injury is inherent.”

It could certainly be argued that mountain biking, a sport that involves a rider on two wheels traveling downhill over a variety of natural surfaces, is an inherently risky sport.  In New York, a mountain biker was injured when he struck a rock and fell at a ski area.  The ski area argued that the mountain biker assumed the risk of injury when he “engaged in the potentially dangerous sport of mountain biking.” The court agreed, noting a voluntary participant in a sport or recreational activity consents to those commonly appreciated risks which are inherent in and arise out of the nature of the sport.  

One Michigan case involving a BMX park may shed some light on liability and bike parks. On his second lap around the track, the rider lost control of his bike while heading toward a jump. The rider was not sure exactly what caused the accident but thought he may have hit a rock or a rut. USA Cycling argued that because the condition of the track was open and obvious, it did not owe a duty of protection or warning. USA Cycling notes that rider was able to observe the track prior to riding, that he rode around the track one time without falling, and that he was able to get a feel for the track conditions prior to his accident. Thus, according to USA Cycling, there were no hidden dangers present and it cannot be held liable for the accident. The Court agreed noting:

  • The BMX cyclist was able to casually inspect the track and the track conditions before his accident by watching other bikers on the track and then riding on the track once himself. A reasonable person in this position would foresee the dangers the track presented, making the condition of the track open and obvious. In fact, most Americans have ridden bicycles in their youth and know that bike riders lose control of their bikes in loose dirt or that a rock will cause a bike to tip over.

Interestingly the court also commented on the risks of biking in general: "Thousands of people ride bikes everyday, and many of them fall while riding their bikes on sidewalks, bike paths, tracks or trails. Bumps, bruises, and scrapes, or occasionally broken bones or more serious injuries, are the normal incidents of bike riding, especially BMX bike riding as in this case."

Could failure to maintain a trail be considered gross negligence?  

There are several lawsuits alleging that landowners can be held negligent for failure to maintain a trail:

  • Michigan: ATV rider was injured while using a public trail. Suit was filed against a tourist association and cycling conservation club alleging the state had contracted with the club to maintain the trail. The court indicated the legislative intent was to limit the scope of protection of the RUS. The court determined the tourist association was not an “owner” under the RUS as the association had received a grant to make trail improvements.  The cycling conservation club was dismissed by stipulation.

  • New York:  A mountain biker was injured when he hit a small pile of sand located at the bottom of a short steep dirt trail. He sued Bethpage state park, alleging failure to maintain the trail. The court determined that the State took into account that participants would act reasonably in light of obvious risks, taking special note that sand is not uncommon on Long Island, the known propensity of mountain bikers to jump, and an available alternate route around the sand pile.  The landowner’s duty is to maintain its land as safe as it appears keeping in mind normal and foreseeable risks encountered in the use of the trail.  In finding no liability on the State, the court ruled “certainly the burden on the State of making its woodland parks totally safe for off-road bikers who disregard known and obvious dangers unreasonably outweighs any risk such bikers could be reasonably deemed not to have assumed.”


RUS provide liability protection but that protection can be lost depending on the facts of the case and the interpretation of the RUS by the court.  However, landowners may be able to look to other legislation and the rules of court for favorable resolution.

Deterring lawsuits:

It’s not uncommon though for injured parties to enter into a contingency fee agreement with their attorney.  If the plaintiff wins the case, the attorney is paid from the proceeds. If the plaintiff loses, no fee is paid.  Therefore, there is less financial risk for the injured person to file suit. Colorado, Maine, and New Hampshire have made it more difficult for plaintiffs to sue landowners by allowing for the award of attorney fees and costs to the prevailing party.  Injured parties may be less likely to file suit knowing they could be responsible for the other party’s fees if their suit is unsuccessful.

Legislation that limits the amount of money that can be awarded can act as a deterrent to filing lawsuits.  Colorado and Texas limit the amount of money that can be awarded to a plaintiff.  In Colorado if liability is found, damages are limited to $350,000 per individual with a  maximum total award of  $990,000.  Texas limits money damages to private landowners to $1,000,000.


Non-profit organizations and their volunteers are also wary of being sued. Adopt-a-trail and similar legislation provides protection, and in some cases, benefits, for volunteers.

Consider these examples:

  • In 2014, Michigan enacted the Adopt-a-Trail program. While the volunteer is working on an adopt-a-trail project, the volunteer has the same immunity from civil liability as a department employee and is to be treated in the same manner as an employee.

  • Minnesota has a  state trail volunteer program through the department of natural resources.  Volunteers are covered under the Department program for worker’s compensation and liability insurance.

  • New York has the Adopt-a-Natural Resource program.  Volunteers and participants are given the same liability and workers compensation protection as employees.  They are also given a formal opportunity to propose activities, including establishing trails.

  • Utah does not have a state adopt-a-trail program but volunteer workers are allowed under the Department of Natural Resources and are considered employees for liability purposes.

  • The Vermont Trails System Act provides that no public or private landowner whose land is part of the Vermont trail system is liable for injuries.

Volunteers can seek liability protection from the Volunteer Protection Act (VPA) and from state volunteer protection statutes though they are rare in the United States.

Under the VPA, a volunteer will not be held liable for harm he or she causes to a person while negligently performing services for a nonprofit organization or government entity. The VPA only applies to uncompensated volunteers who help 501(c)(3) and 501(c)(4) nonprofits and protects volunteers against claims of negligence.  Volunteers may be sued for gross negligence, willful or criminal misconduct, reckless misconduct or conscious, flagrant indifference to the rights or safety of the injured party.  However, the nonprofit organization may still be held liable.  

In addition, some states have also adopted legislation providing some immunity from civil suits to volunteer organizations.  In some cases, the protection is limited only to officers and directors while others provide immunity to individual volunteers.  In general, the nonprofit organization does not have immunity although Arkansas, Colorado, Hawaii, New Hampshire, Maryland, Maine, Kansas, North Carolina, and West Virginia have provisions limiting liability to available insurance coverage.

In Massachusetts nonprofit tort liability is limited to $20,000 as long as the tort was committed in the course of any activity carried on to accomplish directly the charitable purpose of the organization.


For most of American history, sovereign immunity protected federal and state governments, and their employees, from being sued.  In 1946, the Federal Tort Claims Act waived immunity to suit and liability for some actions. Federal Tort Claims Act (FTCA) defines the scope of the federal government's liability. Under the FTCA, the federal government is liable for negligence like a private individual would be under the law of the jurisdiction where the injury occurred.

State tort claims acts are similar to the FTCA in that they define the scope of government liability.  Some states follow the Federal Tort Claims Act and hold public agencies to the same negligence standards as private landowners. Therefore, public agencies may use recreational use statutes and governmental immunity statutes to escape liability for recreation user injuries.

Some states have gone beyond the Recreational Use Statute and enacted recreational liability immunity legislation specifically for public agencies. For example, California's State Tort Claims Act specifically provides immunity on public unimproved lands.

In at least 33 states, the state tort claims act limits the amount of monetary damages that may be recovered.

Some states have adopted Inherent Risk statutes concerning risky sport activities such as skiing, snowmobiling, and skateboarding. The provisions of these statutes seek to curtail liability and lawsuits related to injuries from the inherent risks of these sports. Ski operator statutes have been enacted in many states.  In general, the skier assumes the risk of injury from certain natural and man-made hazards common to the sport of skiing, thereby limiting or relieving altogether the ski area operator’s duty to protect the skier from harm.  

Immunity for volunteers, volunteer organizations, and landowners continues to evolve through new legislation and court interpretation.  It is important for these groups to stay abreast of changes that are occurring within in their states.