Stockberger v. United States

Brief Fact Summary.

Stockberger’s wife sued the United States after her husband’s employer allowed him to leave the premises during a diabetic episode and died after colliding into a tree.

Synopsis of Rule of Law.

A property owner has no duty to rescue someone on the property if the owner has no special relationship with the person.

Facts.

Maurice Stockberger (Stockberger) was an insulin-dependent diabetic and his coworkers at a federal prison were aware of his diagnosis. After telling a coworker that he was having an episode, Stockberger drove home and the coworker did not stop Stockberger from leaving nor did the coworker call for any help from Stockberger’s supervisor or wife. Stockberger collided into a tree and died. Stockberger’s wife sued the United States claiming that the federal prison breached a duty of care by not stopping Stockberger from driving the night of his death. The District Court granted summary judgment in favor of the federal government, and Stockberger’s wife appealed.

Issue.

Whether a property owner has a duty to rescue someone on the property, even if the owner has no special relationship with the person?

Held.

No. The decision of the lower court is affirmed. There is no duty to rescue a person in distress if there is no special relationship.

Discussion.

A defendant has a duty to rescue when a special relationship exists between the parties. A special relationship arises between parties when: (1) the rescuer has a contractual duty to rescue, (2) the victim has no other rescuers and is in the custody of the defendant, and (3) the distress is caused by the rescuer. There is no special relationship that exists where the owner of property has a duty to rescue persons invited onto the premises. Such an exception would create liability for negligence if the owner of the property allowed the invitee to leave, and liability for false imprisonment if the owner of property did not allow the invitee to leave.