Ryals v. United States Steel Corp. Case Brief

Summary of Ryals v. United States Steel Corp. (1990) Pg. 452, 562 So. 2d 192 (Alabama 1990)

Parties: Appellant – Plaintiff – Ryals

Appellee – Defendant – US Steel

Court: Supreme Court of Alabama, 1990

Facts: Plaintiff and his brother trespassed upon the defendant’s property for the sole purpose of stealing scrap metal. In the process of stealing some wiring, the brothers entered into a fenced area and ignored the electrical hazard warning sign. The Plaintiff’s brother, seeing a copper line, grabbed it and in the process received 44,000 volts and suffered burns over 95% of his body causing his death several days later.

Procedural Posture: TC – ruled in favor of summary judgment for US Steel.

Issue: What is the standard of care a property owner owes to a trespasser that enters the owner’s property with the intent of committing a criminal act?

Judgment: Affirmed TC’s decision.

Holding: The standard of care a property owner owes to a trespasser that enters the property with the intent to commit a crime is bound only to refrain from reckless, willful, or wanton conduct toward the trespasser. More specifically, for public policy reasons, 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.

U.S. Steel did not breach its duty, and it did not intentionally injure Ryals, who at the time of injury was an adult illegally upon the U.S. Steel’s property for the purpose of stealing copper wire.

Relevant Rule: The standard of care a property owner owes to a trespasser that enters the property with the intent to commit a crime is bound only to refrain from reckless, willful, or wanton conduct toward the trespasser.

More specifically, for public policy reasons, 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.

Two Distinct Classes of Trespassers

1. Trespassers to whom the landowner owes the duty not to wantonly injure them.

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.

Thought: Do security devices that are used to protect a place from thievery that cause injury to people that break into a place of business hold owners liable to the injuries sustained by the criminal?



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