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Keywords

motionduty of caremotion to dismiss
duty of care

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Anderson v. Chicago Transit Authority, 2019 IL App (1st) 181564, 131 N.E.3d 1245, 433 Ill.Dec. 400

Facts

Jerome Anderson died after falling from a Chicago Transit Authority (CTA) train platform onto the electrified third rail. He had entered the station intending to board a train but lingered on the platform for about 30 minutes without boarding. During this time, he exhibited signs of distress, which his estate claimed were due to a medical emergency related to his diabetic condition. The CTA employees observed him but did not intervene. The CTA filed a motion to dismiss the wrongful death claim, arguing it had no duty to monitor Anderson's condition.

On June 1, 2017, around 9 a.m., decedent allegedly paid his fare and entered the Kedzie-Homan CTA Blue Line station, allegedly to board a Loop-bound train.

Issue

Did the Chicago Transit Authority owe a heightened duty of care to Jerome Anderson, and was it negligent in failing to monitor his condition on the platform?

Did the Chicago Transit Authority owe a heightened duty of care to Jerome Anderson, and was it negligent in failing to monitor his condition on the platform?

Rule

A common carrier owes a heightened duty of care to its passengers, but this duty arises only when a person is in the act of boarding, riding, or alighting from the carrier's vehicle.

A common carrier owes a heightened duty of care to its passengers, but this duty arises only when a person is in the act of boarding, riding, or alighting from the carrier's vehicle.

Analysis

The court analyzed whether Anderson was a passenger at the time of his fall. It concluded that he was not, as he had not boarded any train and had lingered on the platform for an extended period. The court found that the CTA had no legal obligation to monitor Anderson's medical condition or intervene, as the circumstances did not create a special relationship that would impose such a duty.

The court analyzed whether Anderson was a passenger at the time of his fall. It concluded that he was not, as he had not boarded any train and had lingered on the platform for an extended period.

Conclusion

The court affirmed the dismissal of the case, concluding that the CTA did not owe a duty to protect Anderson from falling onto the tracks, as he was not a passenger at the time of the incident.

The court affirmed the dismissal of the case, concluding that the CTA did not owe a duty to protect Anderson from falling onto the tracks, as he was not a passenger at the time of the incident.

Who won?

Chicago Transit Authority; the court ruled that the CTA did not owe a heightened duty of care to Anderson as he was not a passenger when the accident occurred.

Chicago Transit Authority; the court ruled that the CTA did not owe a heightened duty of care to Anderson as he was not a passenger when the accident occurred.

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