Sioux City & Pacific Railroad Co. v. Stout
84 U.S. 657, 17 Wall. 657 (1873)
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Rule of Law:
A landowner may be held liable for injuries to trespassing children if the injury is caused by a dangerous condition on the land that the landowner should have reasonably foreseen would attract children, and the landowner failed to take reasonable precautions to prevent the injury.
Facts:
- Sioux City & Pacific Railroad Co. owned and operated a turntable for trains in an open, unfenced area.
- The turntable was located near a hamlet where children and other members of the public often passed by.
- The turntable was not locked or guarded, and its heavy latch, which could have secured it, had been broken and not replaced.
- The Railroad Company's employees were aware that children had previously played on the turntable on other occasions.
- The plaintiff, a child of tender years, along with several other boys, began playing on the turntable.
- While the boys were turning the machine, the plaintiff's foot was caught between the turning rail and the fixed rail, causing a serious injury.
Procedural Posture:
- The plaintiff, a child, sued the Sioux City & Pacific Railroad Co. in a federal trial court to recover damages for his injuries.
- At trial, the defendant's counsel disclaimed any defense based on the plaintiff's or his parents' negligence, arguing only that the company itself was not negligent.
- The jury returned a verdict in favor of the plaintiff.
- The defendant Railroad Company appealed the judgment, and the case was brought before the Supreme Court of the United States.
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Issue:
Is a landowner liable for negligence for injuries sustained by a trespassing child who is attracted to a dangerous, unsecured condition on the landowner's property?
Opinions:
Majority - Mr. Justice Hunt
Yes. A landowner can be held liable for negligence when a trespassing child is injured by a dangerous condition on the property that the owner should have anticipated would attract children. The court reasoned that a child's status as a trespasser does not absolve a landowner from responsibility for injuries resulting from the landowner's own negligence. While a railroad does not owe the same high duty of care to a trespasser as it does to a passenger, it is not exempt from liability for its tortious acts. Here, the jury could justifiably infer negligence because the turntable was a dangerous machine, it was in a location where children were known to play, and the Railroad Company's own employees had seen them there before. The company should have foreseen that children would be attracted to the turntable. Given that simple and inexpensive precautions, like repairing the broken latch, could have prevented the accident, the company's failure to do so constituted a lack of ordinary care and attention. The determination of whether such negligence existed was a proper question for the jury, as different sensible people could draw different conclusions from the undisputed facts.
Analysis:
This case is foundational for the establishment of the 'attractive nuisance' doctrine in American tort law. It carves out a significant exception to the traditional common law rule that landowners owe no duty of care to trespassers beyond refraining from willful or wanton harm. The decision holds that foreseeability of harm to children can create a duty of reasonable care, even towards those unlawfully on the property. This precedent shifted the legal focus from the status of the entrant (trespasser) to the conduct of the landowner, influencing how courts analyze landowner liability for dangerous conditions that are likely to attract and injure children for generations to come.
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