Bethel v. New York City Transit Authority

Brief Fact Summary.

Bethel (Plaintiff) was injured while riding a New York City Transit Authority (Defendant) bus and prevailed on his negligence suit against Defendant. Defendant appealed and argued that it was held to too high of a standard of care.

Synopsis of Rule of Law.

A common carrier is held to the same duty of care as any ordinary tortfeasor.

Facts.

Plaintiff was injured while riding Defendant’s bus when a wheelchair-accessible chair collapsed. Plaintiff sued Defendant for negligence. The judge instructed the jury that common carriers, such as Defendant, have a duty to use the highest degree of care that human prudence and foresight can suggest in maintaining its vehicles and equipment. The jury found for Plaintiff and Defendant appealed, arguing that a common carrier’s duty of extraordinary care was at odds with the concept of negligence in torts.

Issue.

Is a common carrier held to a higher standard of care than ordinary tortfeasors?

Held.

(Levine, J.) No. A common carrier is held to the same duty of care as any ordinary tortfeasor. The single standard is to exercise reasonable care under all of the circumstances of a particular case. The duty of extraordinary care for common carriers is no longer viable. In this case, the jury was instructed under the extraordinary care standard, so the case must be reversed. Reversed and remanded.

Discussion.

The standard of extraordinary care for common carriers developed in the nineteenth century with the introduction of steam train engines and the resulting railroad accidents. The technological advancements and government regulation of the twentieth century led to the heightened standard’s demise.