62 Mich.App. 720, 413 N.W.2d 486 (Mich. Ct. App. 1987).
The Michigan EALA became effective on March 30, 1995. There are no reported decisions under it. Prior to EALA, Michigan courts followed the traditional common law rule that riders on horses assumed the risk that horses might throw them. Elias v. Hess, 327 Mich. 323, 41 N.W.2d 884 (Mich. Sup. Ct. 1950). For non-Michigan cases indicative of the more recent pre-EALA trend toward imposing liability on equine operators, see Galardi v. Seahorse Riding Club, 20 Cal.Rptr. 270, 16 Cal.App. 4th 790 (Cal. Ct. App. 1993) and Mounts v. Knodel, 83 Or.App. 90, 730 P.2d 594 (Or. Ct. App. 1986). The facts in Mount are similar to the facts in the present case. The rider was injured from a fall due to a broken left stirrup on the saddle. Elias is a weak precedent for operators to rely on in view of the above developments.
In a 1996 case involving skiing, Barr v. Mt. Brighton, 215 Mich.App. 512, 546 N.W.2
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