Ryals v. U.S. Steel Corp.

562 So. 2d 192 · Supreme Court of Alabama · 1990

Facts

David Ryals and his brother trespassed onto U.S. Steel's electrical switch rack to steal copper. David was electrocuted by a 44,000-volt line and died. His estate sued U.S. Steel for wantonness, alleging negligent maintenance and prior incidents, but the trial court granted summary judgment.

Issue

Did U.S. Steel owe a duty of care beyond not intentionally injuring David Ryals, a trespasser who was injured while committing theft on their property, thus precluding summary judgment?

Holding

The court affirmed summary judgment for U.S. Steel, holding that a landowner's duty to an adult trespasser injured while committing a crime is only to refrain from intentionally injuring them, and no evidence suggested intentional injury.

Rule

The court established two classes of trespassers: "mere trespassers" to whom landowners owe a duty not to wantonly injure, and "criminal trespassers" (entering with intent to commit a crime) to whom landowners owe only a duty not to intentionally injure.

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Case brief last reviewed 2026-01-07. Prepared by CaseReader from the published opinion.