California

Although California has no ski safety act, the California courts have consistently held that participants in the sport of skiing accept the dangers that inhere in that sport which are obvious and necessary. Connelly v. Mammoth Mountain Ski Area, 45 Cal. Rptr. 2d 855, 857–58 (Cal. Ct. App. 1995), as modified (Oct. 17, 1995). Those dangers have been held to include, but are not limited to, injuries which can result from variations in terrain; surface or subsurface snow or ice conditions; bare spots; rocks, trees and other forms of natural growth or debris; collisions with ski lift towers and their components, with other skiers, or with properly marked or plainly visible snow-making or snow-grooming equipment. (Danieley v. Goldmine Ski Associates, Inc. (1990) 218 Cal.App.3d 111, 123, 266 Cal.Rptr. 749, quoting from Mich.Stat.Ann., § 18.483(22)(2).)” (Wattenbarger v. Cincinnati Reds, Inc., supra, 28 Cal.App.4th at pp. 752–753, 33 Cal.Rptr.2d 732; Ferrari v. Grand Canyon Dories (1995) 32 Cal.App.4th 248, 253, 38 Cal.Rptr.2d 65, internal quotation marks and parallel citations omitted, italics added.) Because of the obvious danger, the very existence of a ski lift tower serves as its own warning. (See Danieley, supra, at p. 122, 266 Cal.Rptr. 749.)