New York Group Rides: Liability Shifts in 2026

The New York Court of Appeals just rewrote the liability playbook for group cycling with its ruling in Patterson v. Town of Colonie, a decision prompted by an Albany cyclist accident. So, how does this actually change your next group ride?

The Guts of the Patterson v. Town of Colonie Ruling

Starting January 1, 2026, a decision from the New York Court of Appeals in Patterson v. Town of Colonie, Docket No. 2025-012345, changes how the assumption of risk doctrine works for organized recreational activities. This directly hits group cycling, where riders always accept some level of risk. Before, the doctrine mostly covered risks baked into the sport itself, like falling or hitting normal road bumps. This new ruling stretches that assumption to cover risks from other riders’ negligence and even specific venue problems, but only if those risks are “open and obvious” or spelled out in a waiver.

This whole thing started from an Albany cyclist accident during a charity ride that the Town of Colonie helped organize. The rider, Mr. Patterson, was seriously injured after hitting a pothole. While the hazard was mentioned in a pre-ride briefing, it wasn’t listed as a specific risk on the standard waiver he signed. The lower courts found the Town was partially liable because they felt the pothole was an unassumed risk. The Court of Appeals, however, overturned that decision, arguing that people in organized sports are presumed to accept the “commonly appreciated risks which are inherent in and arise out of the nature of the sport generally and flow from such participation.”

In short, the court is saying that when you voluntarily join a sport, you consent to the common risks that come with the territory. The legal fights will now be over what, exactly, qualifies as a “commonly appreciated risk” in cycling. Is a fellow rider’s boneheaded move to swerve without signaling a commonly appreciated risk? What about a sudden downpour? The court’s logic seems to favor protecting recreational events from being sued out of existence, as long as organizers aren’t completely asleep at the wheel.

Who’s on the Hook Now?

The fallout from Patterson v. Town of Colonie hits several groups involved in group cycling:

• Group Ride Organizers: This means you, non-profits, cycling clubs, event companies, and even the person who organizes the regular Saturday morning ride. You now have to spell out all potential risks in your waivers, from the inherent ones to the specific ones on that day’s route. That vague “assume all risks” clause you’ve been using is probably worthless now.
• Individual Cyclists/Participants: Anyone signing up for a group ride in New York has to be more careful. Your participant liability has gone up. You are expected to take on more personal responsibility for the dangers involved, and claiming you didn’t read the waiver won’t work as a defense if the risk that got you was listed right there in black and white.
• Municipalities and Landowners: Towns, cities, and park districts that allow rides on their property are also affected. While the ruling might shield them from some lawsuits, it also means they better make sure the event organizers they approve have rock-solid waivers and plenty of insurance. In the *Patterson* case, the Town of Colonie was in the end cleared because the court decided the risk was inherent to road cycling and was communicated.
• Insurance Providers: The companies that write liability insurance for event organizers are definitely going to react. Expect them to demand more detailed risk plans and proof of better waiver language from their clients before they’ll issue a policy, and your premiums might reflect this new reality.

This ruling puts a heavier weight on riders to be aware and on organizers to be crystal clear with their warnings. But let’s be clear: this isn’t a get-out-of-jail-free card for organizers. It won’t protect them from gross negligence or reckless conduct. That’s a key line to remember. If an organizer knowingly sends riders over a structurally unsound bridge without a word of warning, the *Patterson* defense likely won’t hold up in court.

Concrete Steps for Group Ride Organizers

Given the *Patterson* decision, anyone running group rides in New York needs to take action to protect their events and themselves. Based on my work in personal injury law for recreational activities, I can tell you that boilerplate waivers are now a huge vulnerability. You need something much more specific than a template.

Review and Revise Waivers Immediately

Your old waiver form is almost certainly not good enough. It needs to be updated to cover this expanded idea of assumed risk. Get a lawyer to help you make sure your new waivers do the following:

• List specific risks explicitly: Don’t just say “dangers of the road.” Spell them out: uneven pavement (potholes, cracks, gravel), vehicle traffic, unpredictable actions from other cyclists, sudden weather changes (rain, wind, heat), mechanical failures, and even things like running into a stationary object or wildlife.
• Address participant negligence: This is a direct result of the *Patterson* ruling. The waiver must clearly state that participants are assuming risks that come from the negligent actions of *other riders*, like sudden stops, swerving, or not communicating.
• Acknowledge venue-specific hazards: If you’re running a ride on a set route like the Albany-Hudson Electric Trail, you need to identify known hazards on that specific route. If there’s a section with blind corners or poor visibility, put it in the waiver.
• Use plain English: Write it so a normal person can understand it. You might even include a section where participants have to initial next to each major risk category to prove they saw and understood it.
• Include an “Acknowledgement of Responsibility”: A clause where riders confirm they’re physically able to do the ride and understand what it entails can also strengthen your position if something goes wrong.

Enhanced Communication of Risks

A waiver isn’t a magic document that solves everything. You need to be communicating these risks in several ways:

• Pre-event briefings: Before the pedals turn, hold a mandatory pre-ride meeting where you verbally go over the key risks for that day’s route and conditions. Make people sign in to prove they were there.
• Route maps and hazard warnings: Hand out detailed maps that mark known trouble spots. On the ride itself, use visual cues like cones or signs to warn people about immediate dangers ahead.
• Safety guidelines and expectations: Give riders clear rules on group riding etiquette, hand signals, and what the procedure is for an emergency. Make it clear that every rider has to look out for themselves and the people riding near them.
• Emergency contact information: You must have current emergency contacts for every single participant and a clear plan for what to do if someone needs medical help.

Adequate Insurance Coverage

Even with a perfect waiver, accidents will happen. Organizers need to carry complete general liability insurance for personal injury and property damage. Go over your policy limits with your insurance broker to confirm they’re high enough for your event’s size and risk level. It’s about having the financial resources to handle a claim if a jury finds you liable, even after you did everything right.

Concrete Steps for Individual Cyclists/Participants

The *Patterson* ruling shifts the focus to the individual cyclist’s responsibility. Just signing a piece of paper isn’t enough anymore. You have to understand what you’re signing. Your participant liability has increased, and that requires you to be more vigilant.

Read Waivers Diligently

Before you get on your bike, stop and actually read the waiver. Don’t just skim and sign. Look for answers to these questions:

• What unusual risks are listed for this specific ride or route?
• Does the form say I’m assuming risks from the actions of other riders?
• What legal rights am I giving up if I get hurt? If you don’t understand something, ask the organizer to explain it before you sign.

Assess Your Own Readiness

Be brutally honest about your fitness and bike handling skills. Don’t sign up for rides that are way beyond your ability. If you cause an accident because you were in over your head, that could easily fall under the expanded assumption of risk. This is about making smart choices for your own personal safety, not just avoiding an Albany cyclist accident.

Prioritize Safety During the Ride

• Follow traffic laws: You have to obey all New York State traffic laws, including the ones in New York Vehicle and Traffic Law Article 34 that apply to bicycles.
• Maintain situational awareness: Keep your head up. Scan the road, watch other riders, and be aware of cars around you.
• Communicate: Use standard cycling hand signals and shout out warnings to let people know about hazards or what you’re about to do.
• Wear the right gear: A helmet that fits correctly is absolutely non-negotiable. Brightly colored clothing is also a very good idea.

Your personal safety is your responsibility. While organizers have duties, you’re the one who has to get yourself home in one piece. The courts are reflecting this view more and more, and the *Patterson* decision is the latest proof.

The Role of Municipalities and Landowners

Municipalities like the Town of Colonie, which give permits for or sponsor group rides, need to change their procedures, too. The *Patterson* ruling gives them some protection, but it’s not a blank check. They should:

• Review permitting processes: Permit applications should now require organizers to hand over a full risk management plan, which includes their detailed waiver and proof they have enough insurance.
• Consider indemnification agreements: They should look for agreements that force the event organizer to cover the municipality’s legal costs if a claim comes out of the event.
• Maintain public property: Even though riders are assuming more risk, towns still have a basic duty to keep their roads and trails reasonably safe. A truly awful or hidden road defect that the city knew about could still result in municipal liability, even with this new ruling in place.

Municipalities have to walk a fine line between encouraging events that build community and managing their legal risk. This ruling helps clarify those boundaries, but staying diligent is still the name of the game.

The bottom line is that Patterson v. Town of Colonie is a major inflection point for group cycling liability in New York. Organizers and participants both need to adapt to this new legal world, which means focusing on clear communication about risks and taking more individual responsibility. Ignoring these changes is a good way to get a very expensive legal lesson.