User:Yellowleopard/Milus v. Sun Valley Company

Milus v. Sun Valley Company, 525 P.3d 1103 (Idaho 2025), The Idaho Supreme Court ruled on the interpretation of the Responsibilities and liabilities of skiers and the Idaho Ski Area Liability Act and how it relates to establishing liability in cases involving unthinkable skiing accidents.^[1]

The case arose after a skier at Sun Valley Resort collided with snowmaking equipment, and ended up suffering fatal injuries. This raised concerns about the resort's negligence and duty of care under Idaho Law. Upon ruling Idaho Supreme Court decided that the ski area operator had performed its statutory duty by clearly labeling the snow equipment hazard, which concluded in favor of the ski resort.^[1]

In addition to the verdict, Sun Valley Resort was relieved from liability, since the finding of the incident was classified as an inherent risk acknowledged by skiers. The court's decision highlighted that equipment properly marked in accordance with regulations cannot always give cause for negligence claims, even in cases of death. This helped define how Idaho courts assess ski area liability under ISALA.^[1]

Established in 1985, the Idaho Ski Liability Act (ISALA) specifies the risks which skiers a undertake along with the obligations of ski facility operators. This act addresses the inherent hazards associated with skiing, this includes shifting weather patterns, varying terrain, and the presence of any artificial features such as snowmaking equipment. Under certain circumstances, operators must put up signs and mark potential hazards in accordance with Idaho Code Section § 6-1103. On the other hand Idaho Code Section § 6-1106 limits liability for injuries caused by equipment that is clearly marked and visible. Idaho Ski Area Liability Act (ISALA) is a part of an overall effort in Western states to find a balance among the safety of skiers and the industry's long-term sustainability.^[2]

Among the oldest and most popular ski resorts in the US is Sun Valley Resort, which is located in Blaine County, Idaho. The resort which is famous for its luxury lodges and well maintained ski trails, attracts thousands of travelers every winter. To be able to maintain consistent slope conditions during the entire season, Sun Valley makes significant use of their snowmaking technology.^[3]

Alongside ski runs, snowmaking equipment like the Snow Gun 16 will often be placed near or on the side of certain ski runs. These types of equipment are used to blow artificial snow onto the slopes to ensure safe skiing conditions. Resorts commonly cover or wrap the snowmaking equipment with obvious padding, they also post trailhead warning signs alerting visitors when the snowmaking is happening this helps make them visible and lower the chance of injuries. Even with these safety measures, skiers may still be at risk from stationary machinery, especially on busy trails or in a low visibility situation.^[3]

On November 30, 2019, at Sun Valley Resort Dr. Stewart Milus' was skiing on Lower River Run when he ended up colliding with a stationary tower-mounted snow gun (Snow Gun 16) wrapped in yellow padding. The Snow gun was not actively discharging snow at the time of the incident. Dr. Stewart suffered fatal injuries. Milus' wife, Laura Milus', filed a wrongful death lawsuit both individually and on behalf of their minor child, D.L.J. Laura Milus' alleged that the resort failed to comply with Idaho Code § 6-1103 by inadequately warning skiers of snowmaking hazards and failing to post a trailhead notice.^[1]

The case was first heard in Blaine County District Court, where Sun Valley Company moved for summary judgment. The Trial court ruled in favor of the resort, concluding that the snow gun was sufficiently marked and that no notice was required at the trailhead since the equipment was not operating. The court did not address Sun Valley's additional defense under Idaho Code § 6-1106, which limits liability for inherent risks.^[1]

In December 2023, Laura Milus' appealed. The Idaho Supreme Court reversed the lower court's ruling, holding that factual questions remained about the adequacy of the warning marking and the placement of trailhead notices. However, during the rehearing, the Court issued a substitute opinion on June 25, 2025, affirming the original summary judgment but on different grounds: claiming it was barred under Idaho Code § 6-1106 because the equipment was plainly marked and visible.^[1]

Sun Valley claimed that no further warning signs would have been necessary due to the fact that the snow making equipment was not yet in use and it was already clearly visible with padding. Additionally, the company relied on Idaho Code § 6-1106, stating that the claim should be dismissed since the hazard was visible and essential to skiing. Idaho Supreme Court, June 25, 2025, Substitute Opinion.^[2]

Milus defended that a warning sign should have been installed at the beginning of the slope and that Sun Valley's markings of these hazards were inadequate. She argued that the resort had violated its statutory responsibility by neglecting to provide enough warning signs, which ultimately led to her husband's death.^[2]

The majority opinion was written by Justice John R. Stegner. The Idaho Supreme Court recognized the possibility of different opinions regarding the adequate amount of warning signs. The court nevertheless determined that Snow Gun 16 was clearly visible and marked, which made the incident qualify under Idaho Code § 6-1106. Thereby releasing Sun Valley from any liability of the incident. The Idaho Supreme Court upheld the judgment on June 25, 2025.^[4]

This decision by the Idaho Supreme court made the legal obligations of ski area operators under Idaho Ski Area Liability Act (ISALA) clear, this helped confirm how the law views injuries caused clearly visible and marked equipment. This was very significant for skiers since they should be aware of the law which states injuries caused by clearly marked and visible equipment is an inherent risk when you ski at a resort. Another very important part of this decision showed the significance of legislative immunity clauses and the way Idaho courts interpret them.^[2]