Ryals v. U.S. Steel Corp.

562 So. 2d 192 · Supreme Court of Alabama · 1990

Facts

David Ryals and his brother trespassed onto U.S. Steel's Muscoda Mines switch rack to steal copper. David contacted a 44,000-volt line, suffering severe burns and dying days later. The site had an open gate, dangling wires, and signs of prior stripping.

Issue

What is the appropriate standard of care owed by a landowner to an adult trespasser who is injured while committing a crime on the property?

Holding

The court affirmed summary judgment for U.S. Steel, holding that the landowner's duty to a trespasser committing a crime is only not to intentionally injure them, and no intentional injury was shown.

Rule

Landowners owe a duty not to intentionally injure trespassers who enter with the manifest intent to commit a criminal act. For "mere trespassers," the duty is not to wantonly injure.

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