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Recreational Immunity

By: Derek Hawkins//March 20, 2022//

Recreational Immunity

By: Derek Hawkins//March 20, 2022//

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7th Circuit Court of Appeals

Case Name: Dana Ludwig v. United States of America

Case No.: 21-1205

Officials: FLAUM, ST. EVE, and KIRSCH, Circuit Judges.

Focus: Recreational Immunity

After Brent Ludwig drowned in a tragic accident on United States Forest Service property in Oregon, Dana Ludwig, his wife and administrator of his estate, brought an action against the United States under the Federal Tort Claims Act. Dana Ludwig sought damages for both negligence and wrongful death. The district court granted summary judgment for the United States on the basis that Oregon’s recreational use statute protected the government from suit. Dana Ludwig argues on appeal that the district court’s application of Oregon law was erroneous. We agree with the district court and affirm.


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Derek A Hawkins is Corporate Counsel, at Salesforce.


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