Miller v. Arnal Corp.

Brief Fact Summary.

Miller filed suit against Arnal Corp. when he suffered from hypothermia as a guest at the Snow Bowl Lodge.

Synopsis of Rule of Law.

A person who aids another person can abandon the aid unless they put the other person in a worse position than they were in prior to the aid.

Facts.

Miller and four friends left a snow lodge to go on an overnight hiking trip. When a snowstorm hit, the four friends left Miller to seek assistance for Miller as she contracted frostbite. Although Clay stayed with Miller, the four friends were not able to get a sheriff to locate Miller and Clay until the following morning. When Miller suffered severe hypothermia, and got his feet and his finger amputated, he filed suit against Arnal Corp. (Arnal) the owner of the lodge. The trial court granted judgment to Arnal.

Issue.

Whether a person who aids another person can abandon the aid unless they put the other person in a worse position than they were in prior to the aid?

Held.

Yes. The judgment of the trial court is affirmed. Miller was left in the same position he would have been in if there was no rescue mission. Arnal is therefore not liable for the harm suffered by Miller between the abandonment and when he was found by the sheriff.

Discussion.

A person who aids another person can abandon the aid unless they put the other person in a worse position than they were in prior to the aid. If the actor puts the victim in a worse position than they were in prior to the aid, the actor has a duty to provide reasonable care to continue the aid or abandon the aid so that the victim is not subject to an unreasonable risk of harm.