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Poulin v. Colby College, 402 A.2d 846

Facts

On January 3, 1973, Francis Poulin accepted a ride to work with Mr. and Mrs. Tulley, who were also employees at the Scott Paper Company. After dropping Mrs. Tulley off at Colby College, Poulin helped her navigate an icy road to the dormitory. After ensuring she was safe, he attempted to cross the icy road again and fell, resulting in injuries that led to this lawsuit against the college.

On January 3, 1973, plaintiff accepted a ride to work with a Mr. and Mrs. Tulley. Both Mr. Tulley and plaintiff were employed at the Scott Paper Company in Winslow. The plan for that particular morning was to drop Mrs. Tulley at Colby College in Waterville, where she was employed as a dormitory maid, before proceeding to Winslow.

Issue

Did the college owe a duty of reasonable care to the plaintiff, who was injured while assisting a college employee on the campus, and should the distinction between invitees and licensees be abolished?

Did the college owe a duty of reasonable care to the plaintiff, who was injured while assisting a college employee on the campus, and should the distinction between invitees and licensees be abolished?

Rule

A landowner owes the same duty of reasonable care in all circumstances to all persons lawfully on the land, extending the protection previously afforded to invitees to those classified as licensees.

A landowner owes the same duty of reasonable care in all circumstances to all persons lawfully on land, and such does not require a landowner to insure safety of his lawful visitors, but, rather, merely extends protection previously afforded invitees to those persons who had heretofore been classified as licensees.

Analysis

The court determined that the plaintiff was lawfully on the college's land and that the college owed him a duty of reasonable care. The court found that the icy conditions were foreseeable and that the plaintiff's actions in assisting Mrs. Tulley conferred an economic benefit to the college, implying an invitation for him to be on the premises. The jury's determination that the plaintiff was an invitee was supported by credible evidence.

Given the condition of the roadway, of which defendant must have been aware, defendant must have know that Mrs. Tulley would be exposed to great danger by attempting to reach the dormitory. It was therefore foreseeable, in light of the relationship between plaintiff and Mrs. Tulley, I. e., fellow passengers in the automobile taking Mrs. Tulley to work, that plaintiff would alight from the vehicle and aid Mrs. Tulley up the hill.

Conclusion

The Supreme Judicial Court affirmed the judgment of the Superior Court, denying the college's appeal and upholding the jury's verdict in favor of the plaintiff.

We deny the appeal.

Who won?

Francis Poulin prevailed in the case because the court found that the college owed him a duty of reasonable care, which it failed to uphold, leading to his injuries.

Following a three-day jury trial in the Superior Court, Kennebec County, plaintiff Francis Poulin was awarded damages for injuries he sustained in a fall on the campus of Colby College.

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