Rhodes v. Illinois Central Gulf Railroad
665 N.E.2d 1260, 216 Ill. Dec. 703, 172 Ill. 2d 213 (1996)
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Rule of Law:
A landowner has no legal duty to take affirmative action to aid an injured trespasser when the landowner or a condition of the premises did not cause the injury.
Facts:
- Carl Rhodes, 18 years old, became extremely intoxicated after a night of drinking with friends and was involved in a physical tussle where he bumped his head.
- At approximately 5:00 a.m. on November 29, 1986, an Illinois Central Gulf Railroad (ICG) conductor, Raymond Deany, found Rhodes lying face down in an unmanned ICG warming house.
- Deany observed a small amount of smeared blood on the floor near Rhodes's head but saw no blood on Rhodes himself.
- The conductor reported Rhodes's presence to his supervisor, who then had the ICG dispatcher contact the Chicago Police Department at 5:02 a.m. to have Rhodes removed for sleeping in the station.
- Over the next several hours, multiple ICG employees observed Rhodes still lying in the warming house and made several more calls to dispatch and the Chicago police.
- At 10:11 a.m., an ICG police officer, Richard Bilek, arrived, determined Rhodes was highly intoxicated, and arranged for his transport to a hospital.
- Rhodes was transported to the hospital at 11:05 a.m., where he was diagnosed with a massive subdural hematoma.
- Rhodes died the following day from the brain injury, which was not caused by any condition of the ICG station or action by ICG employees.
Procedural Posture:
- Cora Lee Rhodes, on behalf of Carl Rhodes's estate, sued Illinois Central Gulf Railroad (ICG) in the circuit court of Cook County (trial court).
- The trial judge ruled that Carl's legal status as an invitee or trespasser was irrelevant and instructed the jury that ICG owed a duty of ordinary care.
- The jury returned a verdict for the plaintiff, awarding $1,568,000 in damages, and the trial court entered judgment on the verdict.
- ICG, as appellant, appealed the judgment to the Illinois Appellate Court.
- The appellate court affirmed the trial court's judgment.
- The Supreme Court of Illinois granted ICG's petition for leave to appeal.
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Issue:
Does a landowner have a duty to take affirmative action, such as providing medical assistance, to an injured trespasser when the landowner and the conditions of the premises did not cause the trespasser's injury?
Opinions:
Majority - Chief Justice Bilandic
No. A landowner does not have a duty to take affirmative action to aid an injured trespasser whose injury is not caused by the landowner or the premises. The common law generally imposes no duty to rescue an injured stranger, and a special relationship creating such a duty does not exist between a landowner and a trespasser based merely on the trespasser's presence on the property. The 'place of danger' exception does not apply because the danger must arise from a condition or activity on the premises, not from the trespasser's pre-existing injury. Furthermore, neither the defendant's internal policies nor its act of calling the police created a legal duty to provide further aid under a voluntary undertaking theory.
Analysis:
This decision reaffirms the traditional, limited duty owed to adult trespassers under Illinois law. It narrowly construes the 'place of danger' exception, preventing it from being used to impose a general rescue duty on landowners for injuries unrelated to their property. The ruling solidifies the common law principle that there is no general duty to rescue, clarifying that the trespasser-landowner relationship is not a 'special relationship' that would trigger such a duty. This protects property owners from liability for failing to aid trespassers injured by third parties, a significant clarification in premises liability law.
