Holland v. Baltimore & Ohio Railroad

431 A.2d 597, 1981 D.C. App. LEXIS 305
CourtDistrict of Columbia Court of Appeals
DecidedMay 29, 1981
Docket12429
StatusPublished
Cited by52 cases

This text of 431 A.2d 597 (Holland v. Baltimore & Ohio Railroad) is published on Counsel Stack Legal Research, covering District of Columbia Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Holland v. Baltimore & Ohio Railroad, 431 A.2d 597, 1981 D.C. App. LEXIS 305 (D.C. 1981).

Opinions

NEBEKER, Associate Judge:

This appeal arises from trial court orders dismissing appellants’ complaint with respect to appellee Baltimore & Ohio Railroad Company (B & 0), and granting summary judgment on the complaint to appellee Penn Central Transportation Company (Penn Central). The complaint sought damages for injuries suffered by a nine-year-old child who was injured by a train while trespassing on an area of railroad right-of-way where the two appellees maintain contiguous tracks.

In granting B & 0’s motion to dismiss for failure to state a claim upon which relief could be granted, the trial court utilized the standard set by Firfer v. United States, 93 U.S.App.D.C. 216, 208 F.2d 524 (1953), and dismissed because the complaint failed to allege a willful, wanton, or intentional injury.1 In so doing, the trial court ruled that the attractive nuisance theory of liability, which formed the basis of the complaint, was not available on the facts as pleaded. The court recognized that

[t]he present state of the law in this jurisdiction, Bethea v. United States [D.C.App., 365 A.2d 64 (1976), cert, denied, 433 U.S. 911, 97 S.Ct. 2979, 53 L.Ed.2d 1095 (1977)], is that the doctrine of attractive nuisance “does not extend to things which become dangerous only when adults set them in motion” such as a moving railroad car. Harris v. Roberson, 78 U.S.App.D.C. 246, 139 F.2d 529 (1943). Here of course, the plaintiff was struck and injured by a moving train therefore he may not assert the attractive nuisance doctrine.

The court applied the same law in granting Penn Central’s motion for summary judgment.2

[599]*599A division of this court which originally heard the appeal affirmed the trial court’s decision as to Penn Central, but reversed and remanded as to B & O. Holland v. Baltimore & Ohio R. Co. (No. 12429, June 15, 1979), vacated September 21, 1979.3

Having granted appellee B & O’s petition for rehearing en banc, we are now called on to decide whether the Firfer rule should be abandoned, and if it is not, whether the attractive nuisance exception is available to appellants. We conclude that Firfer v. United States, supra, continues to represent the general rule of landowner liability to trespassers in this jurisdiction. We further hold that the narrow attractive nuisance doctrine exception to the general rule is not applicable in this case as a matter of law.

Since, as the trial court recognized, the same law concerning the general duty of landowners to trespassers and the availability of the attractive nuisance exception is outcome determinative as to both appellees, a unitary analysis is appropriate.

I. THE GENERAL RULE

In 1953, the United States Court of Appeals for the District of Columbia Circuit set the standard to be applied in suits by trespassers against landowners for injuries suffered on the landowners’ property. Trespassers may only recover for “intentional, wanton or willful injury or maintenance of a hidden engine of destruction.” Id. 93 U.S.App.D.C. at 219, 208 F.2d at 528. Firfer has never been overruled in the District of Columbia. Appellants urge, however, that we now abandon Firfer in favor of a “reasonable care under the circumstances” standard, as adopted in 1972 by the circuit court in Smith v. Arbaugh’s Restaurant, Inc., 152 U.S.App.D.C. 86, 469 F.2d 97 (1972). While it is clear that this court sitting en bane may overrule otherwise binding precedent such as Firfer, we decline to do so in this instance.

We recognize that there has been some movement here, and in other jurisdictions, in the direction of abolishing the distinctions between invitee and licensee plaintiffs on the question of the duty of care owed them by landowners. However, the trespasser classification has not been included in this movement in the overwhelming majority of such jurisdictions, including the District of Columbia.4 See Alston v. Baltimore & Ohio R. Co., 433 F.Supp. 553 (D.D.C.1977), W. Prosser, Law of Torts § 62, at 398 (4th ed. 1971). In Blumenthal v. Cairo Hotel Corp., D.C.App., 256 A.2d 400 (1969), and D. C. Transit System, Inc. v. Carney, D.C. App., 254 A.2d 402 (1969), this court adopted a reasonable care standard as to plaintiffs viewed as invitees or licensees. Carney involved a common carrier sued by a passenger for injuries suffered as a result of an abrupt stop made by the carrier’s vehicle. In reversing the trial court’s award of damages to the passenger, we stated that the carrier was held to a standard of care commensurate with the particular hazards involved. In Blumenthal, we [600]*600sustained a summary judgment in favor of a landlord who was sued for alleged negligence in failing to maintain in working order a window lock in plaintiff/lessee’s apartment. Plainly, landowner liability to trespassers was not an issue in either of these cases.

Appellants’ argument for adopting a single standard of care as to trespassers is primarily based on Smith v. Arbahgh’s Restaurant, Inc., supra. There, the plaintiff, a health inspector, suffered a back injury when he slipped on a restaurant stairway while making an inspection. In denying recovery, the circuit court stated its intention to discard the common law theories which determined liability of a landowner by reference to the status of the entrant upon the property, and then concluded: “[a] landowner must act as a reasonable man in maintaining his property in a reasonably safe condition in view of all the circumstances .. . . ” Id. 152 U.S.App.D.C. at 89, 469 F.2d at 100.

The attempt in Arbaugh’s to rewrite the general law of tort liability of landowners in the District of Columbia failed for two reasons. First, the issue of the duty of care owed a trespasser by a landowner was not before the court. Judge Leventhal noted this fact in his concurrence in Arbaugh’s, id. 152 U.S.App.D.C. at 97, 469 F.2d at 108, and in his concurrence in a later case brought by an injured guest against his hosts, Cooper v. Goodwin, 155 U.S.App.D.C. 449, 454, 478 F.2d 653, 658 (1974).5

Judge Leventhal’s concurrence in Cooper also noted the second reason why the abolishment of plaintiff classifications in Arbaugh’s should not be given effect. At the time the Arbaugh’s decision was handed down, the circuit court was “no longer the authoritative expositor of the common law of the District of Columbia.” Cooper v. Goodwin, supra. The criteria for determining whether an opinion of the United States Court of Appeals for the District of Columbia Circuit constitutes binding precedent in this jurisdiction are set forth in M.A.P. v. Ryan, D.C.App., 285 A.2d 310 (1971). Decisions of the circuit court issued prior to February 1, 1971, the effective date of court reorganization, “constitute the case law of the District of Columbia.” M.A.P. v. Ryan, id. at 312.

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Bluebook (online)
431 A.2d 597, 1981 D.C. App. LEXIS 305, Counsel Stack Legal Research, https://law.counselstack.com/opinion/holland-v-baltimore-ohio-railroad-dc-1981.