Boyette v. Trans World Airlines, Inc.

Brief Fact Summary.

Boyette filed a wrongful death suit against Trans World Airlines, Inc. after her son became intoxicated on an airplane and evaded airport security by jumping into a trash chute, ultimately leading to his death.

Synopsis of Rule of Law.

A common carrier is relieved of the duty of protecting passengers once the passengers reach a place of safety.

Facts.

Rutherford became intoxicated after flying on Trans World Express (Trans) with three co-workers. When getting off the plane, Rutherford went into a restricted area and climbed onto a luggage tug. When Rutherford found out that airport security was called on him, Rutherford went to the terminal and stole a gold cart. Callier, a trans agent, chased Rutherford into a cleaning room where Rutherford slipped into a trash chute and was subsequently crushed and killed. Boyette, Rutherford’s mother, filed a wrongful death suit and the trial court granted summary judgment to the defendants.

Issue.

Whether a common carrier is relieved of the duty of protecting passengers once the passengers reach a place of safety?

Held.

Yes. The judgment of the trial court is affirmed. Trans’ duty to Rutherford ended once Rutherford reached the tarmac.

Discussion.

A common carrier is relieved of the duty of protecting passengers once the passengers reach a place of safety.