Ryals v. United States Steel Corp.
562 So. 2d 192 (1990)
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Rule of Law:
A landowner owes a reduced duty of care to an adult trespasser who enters the land with the manifest intent to commit a criminal act; this duty is to refrain from intentionally injuring the trespasser, as opposed to the higher duty of refraining from wantonly injuring a mere trespasser.
Facts:
- On March 31, 1984, brothers David Ryals and Wilson Ryals trespassed onto a U.S. Steel Corporation property known as the Muscoda Mines switch rack.
- Their purpose for entering the property was to steal copper, brass, and other salvageable metals.
- Upon arriving, they observed that the area was in a state of disrepair, with a detached warning sign, dangling wires, and a gate that was wide open.
- The switch rack was surrounded by a chain link fence topped with barbed wire, and there was at least one sign warning of electrical danger.
- While attempting to steal materials, David Ryals came into contact with a 44,000-volt copper line.
- David Ryals suffered third-degree burns over 95% of his body and died several days later from his injuries.
Procedural Posture:
- Wilson Ryals, Jr., as administrator of David Ryals's estate, sued United States Steel Corporation in the trial court, alleging negligence and wantonness.
- The plaintiff voluntarily dismissed the negligence claim.
- The trial court granted summary judgment in favor of the defendant, U.S. Steel, on the remaining wantonness claim.
- The plaintiff, Wilson Ryals, Jr., appealed the trial court's summary judgment to this court.
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Issue:
Is a landowner's duty of care to an adult trespasser, who enters the property with the manifest intent to commit a crime, limited to refraining from intentional injury rather than wanton injury?
Opinions:
Majority - Per Curiam
Yes. A landowner's duty of care to an adult trespasser who enters the property to commit a crime is limited to refraining from intentional injury. The court establishes two distinct classes of trespassers for the purpose of premises liability. While a landowner owes a duty not to wantonly injure a 'mere' trespasser, public policy justifies a lower standard of care for a trespasser who enters land with the manifest intent to commit a crime. In this case, there is no evidence that U.S. Steel intentionally injured David Ryals; the presence of a fence, barbed wire, and warning signs, despite the unlocked gate, indicates no intent to harm. Therefore, applying this lowered standard of care, U.S. Steel did not breach its duty to David Ryals, and summary judgment was appropriate.
Concurring - Unspecified Justice
The justice agrees with the result but writes separately to emphasize that the new rule applies specifically to trespassing adults, noting that the duty owed can depend on the age of the trespasser. The author also expresses concern that the new rule could create confusion in future cases involving different types of criminal trespass, such as hunting on posted land. Due to these potential ramifications, the concurrence is in the result only.
Analysis:
This decision is significant for creating a new sub-class of trespasser in premises liability law, thereby lowering the standard of care landowners owe to individuals injured while committing crimes on their property. By distinguishing between 'mere trespassers' and 'criminal trespassers,' the court carves out a public policy exception that protects property owners from liability for wantonness toward those with criminal intent. This precedent makes it substantially more difficult for a person injured during the commission of a crime to recover damages from a landowner and may influence other jurisdictions to adopt a similar distinction.
