Sioux City & Pacific Railroad Co. v. Stout

Sioux City & Pacific Railroad Co. v. Stout, 84 U.S. (17 Wall.) 657 (1873), was a case decided by the Supreme Court of the United States that first enunciated the idea that a landowner could be liable for the injuries of a child trespasser.

Sioux City & Pacific R.R. Co. v. Stout
Decided January 26, 1874
Full case nameSioux City & Pacific R.R. Co. v. Stout
Citations84 U.S. 657 (more)
17 Wall. 657; 21 L. Ed. 745
Court membership
Chief Justice
vacant
Associate Justices
Nathan Clifford · Noah H. Swayne
Samuel F. Miller · David Davis
Stephen J. Field · William Strong
Joseph P. Bradley · Ward Hunt
Case opinion
MajorityHunt, joined by unanimous

Background

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A railroad turntable similar to this one was thought to breach the duty to children trespassers because it induced them to trespass. The original turntable was torn down in the late 1890s.

On March 29, 1869, a small child was injured by a railroad turntable owned by Sioux City and Pacific Railroad, which was being operated in Blair, Nebraska. The child was playing on the turntable, which injured his/her foot. The father took the company to court in the federal Circuit Court for the District of Nebraska. After a first jury trial failed to reach a decision, a second jury awarded the father $7,500 in 1872.[1][2] The railroad then sought a writ of error from the Supreme Court.

Decision

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A child was injured by a railroad turntable owned by Sioux City and Pacific Railroad, which was being operated in Blair, Nebraska. Sioux City & Pacific Railroad company was held liable, despite the prevailing idea that a landowner was not held liable for injuries to trespassers. Trespassing children were thought to be a special case that required a higher duty of care. This theory of liability came to be known as the "turntable doctrine" and later the attractive nuisance doctrine by the case Keffe v. Milwaukee & St. Paul R.R. Co.

See also

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References

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  1. ^ Hudson, Manley O. (May 1923). "The Turntable Cases in the Federal Courts". Harvard Law Review. 36 (7): 829–830. doi:10.2307/1328445. JSTOR 1328445.
  2. ^ 84 U.S. at 659.