Ryals v. United States Steel Corporation
Subject: the traditional duty owed to trespassers (those who enter to commit a crime).
FACTS
Two individuals trespassed on defendant's mines/land to strip metals. They found the area in decay. The plaintiff contacted a copper line of high voltage, and suffered burns resulting in death.
Two individuals trespassed on defendant's mines/land to strip metals. They found the area in decay. The plaintiff contacted a copper line of high voltage, and suffered burns resulting in death.
RULES
1. Legal duty owed by a landowner to a trespasser: Lowest standard of care.
Refrain from reckless, willful, or wanton conduct towards trespasser.
2. Legal duty owed by a landowner to a mere trespasser.
Not to recklessly or wantonly injure the person.
ISSUE
What duties are owed to trespassers?
HOLDING
The duty owed by a landowner to an adult trespasser who comes upon the land and is injured while committing a crime is the duty not to intentionally injure such trespasser.
Course: Tort Law
Subject: Duty
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Ryals v. US Steel Corp., 562 So. 2d 192 - Ala: Supreme Court 1990
ReplyDeleteWilson Ryals, Jr., as administrator of the estate of his brother, David Ryals, appeals from a summary judgment in favor of the defendant, United States Steel Corporation ("U.S. Steel"). The plaintiff alleged that the defendant caused the decedent's death by negligently or wantonly failing to maintain and secure a "switch rack."[1] Ryals later voluntarily dismissed the negligence claim, and the trial court entered summary judgment in favor of U.S. Steel on the wantonness claim.
Because this Court, by this opinion, recognizes two distinct classes of trespassers to land—(1) mere trespassers, to whom the landowner owes the duty not to wantonly injure them; and (2) trespassers who enter upon the land of another with the manifest intent to commit a criminal act and to whom the landowner owes only the duty not to intentionally injure them—we affirm the judgment.
On March 31, 1984, Wilson and David Ryals, as trespassers, went to U.S. Steel's Muscoda Mines switch rack for the purpose of "stripping out" copper, brass, and other salvageable metals. Wilson Ryals testified at his deposition that, when they arrived at the site, they found the base of the structure to be partially stripped; that they found one rusty warning sign, detached metals lying on the ground, dangling wires, garbage in and around the fenced area and wild vegetation growing around the fence; and that they found the gate leading into the switch rack to be "wide open." David Ryals contacted a 44,000-volt copper line; he suffered third degree burns over 95% of his body and died several days later as a result.
The only issue presented here is whether U.S. Steel was entitled to a summary judgment under the appropriate standard of care owed by U.S. Steel to David Ryals, as a trespasser, who, at the time of his injury, was engaged in the crime of theft of U.S. Steel's property. Rule 56, A.R.Civ.P., sets forth a two-tiered standard for granting summary judgment. That rule requires the trial court to determine 1) that there is no genuine issue of material fact, and 2) that the moving party is entitled to a judgment as a matter of law.
Read more: http://scholar.google.com/scholar_case?case=1651745108054957973&hl=en&as_sdt=6&as_vis=1&oi=scholarr