When Trampoline Parks Can’t Bounce Away from Liability: PA Superior Court Reverses Summary Judgment in Ristaino v. Urban Air

By Jason Javie October 30, 2026

Commercial trampoline parks are a staple of modern weekend fun for kids and adults alike. But behind the bright neon lights, foam pits, and high-flying acrobatics lies a complex legal landscape. When a jumper gets hurt, is it just an unfortunate "risk of the game," or is the facility on the hook for failing to maintain its gear?

In a precedential decision issued today— Ristaino v. Urban Air Downingtown, et al. , 2026 PA Super 245—the Superior Court of Pennsylvania addressed this exact clash. The court held that commercial recreation facilities cannot hide behind the well-known "no-duty" rule when a patron’s injury stems not from the ordinary, inherent hazards of jumping, but from defective, worn-out equipment and lax safety maintenance.

Here is a breakdown of what happened, the core legal principles at play, and why this ruling matters for both personal injury practitioners and everyday recreation-seekers.

The Incident: A Routine Jump Turns Serious

On March 10, 2022, 42-year-old Michael Ristaino visited the Urban Air trampoline park in Downingtown, Pennsylvania. While jumping down a long trampoline track leading toward a loose foam cube pit, Ristaino lost control of his bounce, sustaining severe injuries, including a wedge compression fracture of his first lumbar vertebra (L1).

Ristaino filed a negligence lawsuit against Urban Air and its related corporate entities. During discovery, his liability experts uncovered several critical facts:

Massive Overuse: The trampoline bed in question was six years and three months old.
Ignored Guidelines: The manufacturer recommended replacing the bed every 6 to 18 months, and Urban Air’s own corporate policy mandated replacement at least every 5 years.
Equipment Degradation: Expert testing revealed a physical depression in the mat. It had turned "soft & spongy," producing an unstable rebound effect known in the industry as "rubber legging," which caused Ristaino to lose control.

Despite this evidence, the Chester County Court of Common Pleas granted summary judgment in favor of Urban Air. The trial judge reasoned that because Ristaino conceded trampolining inherently carries risks of injury, the facility owed him no legal duty.

Ristaino appealed—and the Superior Court reversed.

Deconstructing the Legal Framework

To understand why the Superior Court overturned the trial court's dismissal, we have to unpack two fundamental concepts in Pennsylvania tort law: Duty of Care and the "No-Duty" Rule.

 
///////////////////////// NEGLIGENCE ANALYSIS /////////////////////////
                                   │
                    ┌──────────────┴──────────────┐
                    ▼                             ▼
           Inherent Hazard?              Unanticipated Danger?
       (Common, frequent, expected)    (Defects, neglected maintenance)
                    │                             │
                    ▼                             ▼
             NO-DUTY RULE                OPERATOR REMAINS LIABLE
       (Operator owes no duty)            (Duty of care breached)

1. What is the "No-Duty" Rule?

Under Pennsylvania law, to win a negligence claim, a plaintiff must prove that the defendant owed them a legal duty, breached that duty, and caused actual damages.

In the realm of amusement parks, sports venues, and recreational facilities, Pennsylvania recognizes the "no-duty" rule(first solidified in Jones v. Three Rivers Management Corp. , 394 A.2d 546 (Pa. 1978)). Under this doctrine, operators have no duty to warn or protect patrons against risks that are:

Common
Frequent
Expected

Classic example: If you attend a baseball game and a foul ball flies into the grandstand, that is an inherent, foreseeable risk of watching baseball. The stadium operator is generally shielded by the no-duty rule.

2. The Critical Exception: Unanticipated, Non-Inherent Risks

The no-duty rule is not an all-inclusive shield. It does not relieve an owner or operator from the duty to protect patrons from foreseeably dangerous conditions that are not inherent to the activity.

In Jones , a spectator was struck by a foul ball while walking through an interior stadium concourse where unusual structural openings existed. The PA Supreme Court held the no-duty rule did not apply because openings in an interior walkway were not an ordinary feature of baseball.
In Telega v. Security Bureau, Inc. , 719 A.2d 372 (Pa. Super. 1998), a football fan caught a souvenir football and was tackled and trampled face-first into concrete by aggressive fans. The court held that being trampled by an unruly crowd was not a risk "common, frequent, and expected" when attending an NFL game.

The Superior Court’s Holding: Neglect Is Not an "Inherent Risk"

Writing for the panel in Ristaino , Judge Alice Beck Dubow made a sharp distinction that the trial court missed:

"As a matter of law, jumping on a worn-out trampoline is a risk that is not 'common, frequent, and expected' at a trampoline park. Rather, it is an unforeseeable and unanticipated risk."

While a jumper assumes the standard physical risks of bouncing (like misjudging a landing), a paying customer does not assume the risk that a facility has left equipment in service four to twelve times past its recommended lifespan.

Because Ristaino presented credible expert evidence showing that the worn-out, unstable mat caused his fall, there was a genuine issue of material fact for a jury to decide. The Superior Court reversed the summary judgment order and reinstated Ristaino's complaint.

Key Takeaways

For Amusement & Facility Operators: Safety manuals and manufacturer replacement schedules cannot be ignored. The no-duty rule will not protect you against documented maintenance failures, structural defects, or outdated equipment.
For Personal Injury Litigators: When facing a no-duty or assumption-of-the-risk defense in a sports or recreation setting, the key inquiry is causation. Focus your discovery and expert testimony on differentiating between the general hazards of the sport and the specific, unnatural hazard created by the defendant's conduct.
For Consumers & Families: While physical activities carry natural risks, businesses that open their doors to the public still have a basic obligation to provide reasonably safe, well-maintained facilities.

Need Legal Guidance on a Premises or Recreational Injury?

If you or a loved one suffered a serious injury at a commercial recreational facility, amusement park, or sports complex, don't assume you have no recourse just because the activity carried inherent risks. The difference between an assumed risk and actionable negligence often comes down to equipment maintenance and safety compliance.

Contact our legal team today for a comprehensive case evaluation to explore your options.

Jason Javie | Oct 30 2026 18:07

When Trampoline Parks Can’t Bounce Away from Liability: PA Superior Court Reverses Summary Judgment in Ristaino v. Urban Air