Boyette v. Trans World Airlines, Inc.
954 S.W.2d 350 (1997)
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Rule of Law:
A defendant's duty of care does not extend to protecting a plaintiff from injuries that are the unforeseeable result of the plaintiff's own superseding, intervening actions, and a landowner's duty to a trespasser is limited to refraining from willful or wanton injury.
Facts:
- Joseph Rutherford consumed at least eight alcoholic drinks before and during a Trans World Express (TWE) flight to St. Louis.
- After deplaning onto the tarmac at Lambert International Airport, Rutherford passed under a safety rope and climbed onto an idling luggage tug.
- Upon entering the terminal, Rutherford stole an electric golf cart and began driving it erratically around the gate area.
- A TWE gate agent, Britney Callier, chased Rutherford on foot in an attempt to stop him.
- Rutherford abandoned the cart and hid from Callier in an unlocked cleaning room, Room D-231.
- Inside the room, Rutherford's co-worker, Chris Traylor, assisted him in climbing into a small door on the wall, which was an opening to a trash chute.
- Rutherford fell approximately ten feet from the chute into a large trash compactor below, sustaining injuries from the fall.
- The compactor was equipped with a photoelectric eye that automatically activated the machine when its beam was blocked for more than eight seconds, which ultimately caused Rutherford's death.
Procedural Posture:
- Patricia Boyette, the decedent's mother, filed a wrongful death action against Trans World Express (TWE), the City of St. Louis, and others in a Missouri trial court.
- The petition alleged TWE was negligent for pursuing Rutherford and for failing to ensure his safety after he was found.
- The petition alleged the City was negligent for failing to have an emergency deactivation switch for the compactor, failing to post warnings, and failing to render aid.
- TWE and the City each filed motions for summary judgment, arguing they owed no duty to Rutherford.
- The trial court granted summary judgment in favor of TWE and the City.
- Boyette (Appellant) appealed the trial court's grant of summary judgment to the Missouri Court of Appeals, Eastern District.
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Issue:
Does a common carrier or a premises owner owe a duty of care to an individual whose death results from his own unforeseeable and dangerous actions, specifically climbing into a trash chute after a series of disruptive acts, thereby becoming a trespasser?
Opinions:
Majority - Pudlowski, Judge
No. Neither the common carrier nor the premises owner owed a duty of care to prevent Rutherford's death because his own actions were an unforeseeable, intervening cause of his harm. Regarding TWE, its duty as a common carrier to ensure passenger safety terminated once Rutherford reached a reasonably safe place, which was the airport terminal. While a TWE employee pursued Rutherford after he stole the golf cart, Rutherford's subsequent decision to climb into a trash chute with his friend's assistance constituted an intervening cause that broke the chain of causation. His death was not a reasonable or probable consequence of the pursuit. Regarding the City, Rutherford's status at the time of injury was that of a trespasser, as he entered the cleaning room and trash chute without permission. The duty owed to a known trespasser is to avoid willful or wanton injury and not to set hidden traps; it does not include a general duty to rescue. The trash compactor was not intentionally placed to injure him, so the City breached no duty.
Analysis:
This decision reinforces the common law principles limiting a defendant's duty in tort, particularly through the doctrines of proximate cause and premises liability. It clarifies that a common carrier's heightened duty of care is finite and does not extend indefinitely after a passenger has safely deplaned. The court's application of intervening cause demonstrates how a plaintiff's own highly unforeseeable and reckless conduct can sever the legal connection to a defendant's alleged negligence. Furthermore, the case affirms the traditional, restrictive view of liability toward trespassers, holding that even discovering a trespasser in peril does not create an affirmative duty to rescue.
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