Melinda Smith


Commentators have dubbed volunteers the "third sector" of the American economy, which is otherwise composed of business and government. Various services such as libraries, school boards, scout troops and little league teams depend upon volunteers. However, a series of highly publicized tort actions against volunteers in the 1980's combined with a cycle of increasing insurance premiums and decreasing coverage for volunteers and nonprofit organizations, raised concern within the volunteer community. Over the past several years some jurisdictions afraid of losing volunteer services have made public policy decisions shielding volunteers from liability for their own negligence. This note explores the debate regarding the decision to provide tort immunity for volunteers in the context of the Ohio Supreme Court's opinion in Zivich v. Mentor Soccer Club, Inc.

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