Boyette v. Trans World Airlines, Inc.

954 S.W.2d 350 · Missouri Court of Appeals · 1997

Facts

Joseph Rutherford, intoxicated, deplaned at Lambert International Airport, engaged in erratic behavior, including stealing a golf cart, and was pursued by TWE employees. He then entered an unlocked cleaning room, climbed into a trash chute, fell into a compactor, and died after it activated. His mother sued TWE and the City for wrongful death.

Issue

Did TWE owe a duty of care to Rutherford after he deplaned, and was its pursuit the proximate cause of his death? Did the City owe a duty to Rutherford, a trespasser, regarding the trash compactor's safety or rescue?

Holding

The court affirmed summary judgment for TWE and the City, finding TWE's duty as a common carrier ended upon deplaning and Rutherford's actions were an intervening cause. The City owed no duty to Rutherford as a trespasser beyond refraining from intentional harm.

Rule

A common carrier's duty to passengers ends when they reach a reasonably safe place, and an intervening cause can break the chain of proximate causation. A landowner owes a trespasser only the duty to refrain from intentionally placing hidden dangers or using willful force.

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Case brief last reviewed 2026-01-31. Prepared by CaseReader from the published opinion.