348 So. 2d 287 (Fla. 1977)
The Supreme Court of Florida consolidated three cases for review under its conflict certiorari jurisdiction.1 The District Court of Appeal, Third District, in Dorta v. Blackburn, 302 So.2d 450 (Fla. 3d DCA 1974), concluded that assumption of risk remained an absolute bar to recovery.2 The District Court of Appeal, First District, in Parker v. Maule Industries, Inc., 321 So.2d 106 (Fla. 1st DCA 1975), and the Fourth District in Rea v. Leadership Housing, Inc., 312 So.2d 818 (Fla. 4th DCA 1975), reached opposite conclusions on this issue.3
Subsequently, the First District decided additional cases including Smith v. Carter, 338 So.2d 845 (Fla. 1st DCA 1976), Hambrick v. Jackson, 333 So.2d 96 (Fla. 1st DCA 1976), and Manassa v. New Hampshire Insurance Co., 332 So.2d 34 (Fla. 1st DCA 1976).4 The Second District also addressed the matter in Hall v. Holton, 330 So.2d 81 (Fla. 2d DCA 1976), rejecting the doctrine's continued viability as a complete bar.5
Accordingly, the petition for writ of certiorari to the District Court of Appeal, Third District, in Blackburn v. Dorta, Case No. 46,621, is granted, the decision of that court is quashed, and the cause is remanded for further proceedings not inconsistent herewith. In Leadership Housing, Inc. v. Rea, Case No. 47,621, and in Maule Industries, Inc. v. Parker, Case No. 48,443, the District Court decisions are approved, and writs of certiorari are discharged.6
The cases were decided on May 5, 1977, with rehearing denied on July 27, 1977.7 Justice Sundberg authored the opinion in which Chief Justice Overton and Justices Adkins, Boyd, England, and Hatchett concurred.8
Whether the doctrine of assumption of risk remains viable as an absolute bar to recovery after the adoption of comparative negligence in Hoffman v. Jones?9
The affirmative defense of implied assumption of risk is merged into the defense of contributory negligence, and the principles of comparative negligence apply in all cases where such defense is asserted.10
No. The court analyzed the categories of assumption of risk and determined that primary assumption of risk is subsumed in the negligence analysis itself, while implied-qualified assumption of risk is indistinguishable from contributory negligence.11 Applying this rule to the established facts, the conflicting decisions of the district courts of appeal are resolved by holding that assumption of risk no longer serves as a complete bar, consistent with the comparative negligence framework adopted in Hoffman v. Jones.12 The Third District's decision in Dorta v. Blackburn is quashed, while the decisions from the First and Fourth Districts are approved.
The doctrine of assumption of risk does not remain viable as an absolute bar to recovery after the adoption of comparative negligence in Hoffman v. Jones.13