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Bethel v. New York City Transit Authority

From lawbrain.com

Bethel v. New York City Transit Authority, 703 N.E.2d 1214 (1998), was a tort law case that modified the standard of care to apply to common carriers in suits involving negligence.

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Summary of Case Facts

The plaintiff was a wheelchair-bound individual who was injured when the wheelchair-accessible seat lift collapsed underneath him. While the plaintiff could not prove that the Transit Authority (defendant) had knowledge of the defective seat, they could produce a computer printout with a repair record from eleven days prior of the very seat that collapsed. Plaintiff contended that a reasonable inspection of the chair after the repair would have revealed its defective condition, and as such, the defendant had constructive notice of the defect responsible for the chair’s collapse. The court instructed the jury that a common carrier had the highest standard of care owed to its passengers. Defendant lost, and appealed challenging the instruction on the standard of care.


Should a duty of highest care be applied to common carriers?

Holding and Law

No. The appropriate standard of care applicable to common carriers is the objective reasonable person standard. The court held that there exists a sufficient flexibility and leeway to permit a due allowance to be made for any manner of circumstances involving a tortfeasor that may affect the conduct required. A common carrier is subject to the same standard of care as any other potential tortfeasor.

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