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TOWNS v. DAVIDSON
Under primary assumption of risk doctrine, skier assumes risk of injury resulting from collision with another skier, including an employee of ski resort, even if employee is violating company policies by skiing unsafely. Employee of ski resort did not act recklessly and thus did not increase risks inherent in sport so as to take case outside the primary assumption of risk doctrine where evidence showed that, at worst, employee skied fast and aggressively and was inattentive to plaintiff, who was skiing to his left and whom he did not see in time to avoid collision.

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