Case name and citation: Bethel v. New York City Transit Authority (15 october, 1998)..
Parties: Bethel, The Plaintiff; New York City Transit Authority, The Defendant.
Facts: While using the transit authority’s services, Bethel sat in a wheelchair-accessible seat. The seat collapsed to the floor and caused Bethel severe injuries on the back. Bethel was a wheelchair-bound individual, and there were no protective or defensive measures he could have taken when the seat collapsed underneath him. The plaintiff was not in a position to prove that the transit authority was aware of the defective seat (Casebriefs.com, 2013). The defendant could provide the court with a printout of the repair records eleven days before the incident. The contention of the plaintiff was that an inspection of the chair after the repairs had taken place could have revealed that it was defective. As such, the defendant would have had constructive notice of the defect that would be responsible for the seat defect that made it collapse. The court ruled in favor of the plaintiff, and the defendant appealed the case to challenge the high standard of care that was imposed in this case.
Procedural history: The defendant, New York Transit Authority, was held responsible for the damages and not having acted on the constructive notice. During the proceedings of the case, it was submitted that the defendant had a duty of the highest degree of care as a common carrier. This applied in the maintaining of the equipment and vehicles of the defendant to ensure that they present no danger to the users. The court ruled against the defendant. The defendant appealed the ruling. The Appellate Division affirmed the decision of the lower court. However, the Appellate Division failed to address the issue of “highest degree of care” that was imposed and demanded of the defendant.
Issues: The Court of Appeals was interested in having the defendant prove that future similar incidents were prevented as opposed to the use of constructive notice. The ruling was held as a legal fact that common carriers such as the defendant have a duty of the highest degree of care possible for the passers. The issues, therefore, were as follows:
- Does a common carrier have a duty of extraordinary care for the users of its services?
- If not, what duty does a common carrier owe the passengers?
Holding: The courts held that the duty of extraordinary care is no longer applicable in the modern context of common carriers. It has been replaced by the duty of reasonable care.
Reasoning: The duty of extraordinary care was necessary in the 19th century when railroads were the dominant common carriers. The railcars at the time were very dangerous and unreliable, requiring that the highest maintenance standards be adopted to ensure safety. The Court of Appeals indicated that it would be unreasonable to enforce outdated standards on the defendant (LawBrain, 2011). Therefore, it is possible to modify a duty of reasonable care through a case-by-case analysis, as it is practical to make the highest care that one can provide a requirement for the common carriers.
Decision: The New York Trial Court ruled in favor of the plaintiff; the New York Appellate Division affirmed the decision; and New York Court of Appeals remanded the decision.
Comments: This case marked a change in the duty of care required by common carriers by law (LawBrain, 2011). It was changed from extraordinary care to reasonable care.
Bethel v. New York City Transit Authority (1998) 703 N.E.2d 121.
Casebriefs.com. (2013). Bethel v. New York City Transit Authority | Casebriefs. Retrieved from https://www.casebriefs.com/blog/law/torts/torts-keyed-to-franklin/the-negligence-principle/bethel-v-new-york-city-transit-authority/
LawBrain. (2011). Bethel v. New York City Transit Authority – Lawbrain.com. Retrieved from http://lawbrain.com/wiki/Bethel_v._New_York_City_Transit_Authority