Joann Ravell v. United States

Joann Ravell, who tripped and fell at an air show held at Norton Air Force Base in San Bernardino, California, brought this action for negligence against the United States. The United States asserted that under California’s recreational use statute it owed her no duty and was, therefore, immune. Cal. Civ.Code § 846. The district court agreed. It granted summary judgment against Ravell and she appealed. We affirm. t

BACKGROUND

Norton Air Force Base is a military installation which is normally closed to the general public. However, for November 12, 1988, the general public was invited to enter the base to attend a free air show. The event was widely publicized in newspapers and was attended by 300,000 people. Members of the public were allowed into normally closed parts of the base like the flight line, where aircraft were often parked and tied down to hooks. The tie-down hooks were very large steel eyelets which were embedded in the concrete of the flight line flush with its surface.

Ravell went to the air show, tripped over one of the hooks, fell, and sustained injuries. She then sued the United States. Her presence on the base was simply as a member of the general public,…