DiBenedetto v. CSX Transp., Inc., 8 N.Y.3d 973 (2007)
Landowners are generally not required to illuminate their property during all hours of darkness absent a hazardous condition or other circumstance giving rise to such an obligation.
Summary
Plaintiff DiBenedetto was injured when he tripped on a ramp in CSX’s railroad yard during a power outage. He sued CSX, alleging negligence for failure to provide adequate lighting. The Court of Appeals affirmed the dismissal of the complaint, holding that CSX was entitled to summary judgment because the plaintiff failed to demonstrate that CSX breached a duty of care. The court reasoned that landowners are not generally required to illuminate their property at all times unless a hazardous condition exists. Furthermore, CSX had provided lighting, and the darkness was due to a power outage beyond their control, which the plaintiff was aware of.
Facts
Plaintiff DiBenedetto was injured in a railroad yard owned by CSX Transportation, Inc. At the time of the injury, a power outage had caused the yard to be dark. DiBenedetto tripped on the ramp of another truck within the yard. CSX provided lighting in the yard, but it was inoperable due to the power outage. DiBenedetto was aware of the power outage and the resulting darkness when he entered the property.
Procedural History
The trial court initially ruled in favor of CSX. The Appellate Division reversed that decision. CSX appealed to the New York Court of Appeals.
Issue(s)
Whether CSX, as the owner of the railroad yard, breached a duty of care to DiBenedetto by failing to provide adequate lighting, when the darkness was due to a power outage, a condition CSX did not cause or control, and of which DiBenedetto was aware.
Holding
No, because the plaintiff failed to demonstrate that CSX breached a duty of care it owed him.
Court’s Reasoning
The Court of Appeals held that CSX was entitled to summary judgment because DiBenedetto failed to raise a triable question of fact as to whether CSX breached a duty of care. The court relied on the principle that landowners are generally not required to illuminate their property during all hours of darkness unless there is a hazardous condition or other circumstance that creates an obligation to provide exterior lighting. The Court cited Peralta v Henriquez, 100 NY2d 139, 145 (2003) in support of this proposition.
The Court emphasized that CSX had, in fact, provided lighting in the railroad yard. The darkness was caused by a power outage, a problem CSX did not cause or control. Furthermore, DiBenedetto was aware of the power outage when he entered the property. Because DiBenedetto failed to provide proof that his injury, caused by tripping on the ramp of another truck, was attributable to negligence on the part of CSX, the Court of Appeals reversed the Appellate Division’s decision and reinstated the initial ruling in favor of CSX.
The court found no evidence that CSX’s actions or inactions caused the power outage or created a hazardous condition that would require additional lighting beyond what was already provided. The ruling underscores the principle that landowners are not insurers of the safety of individuals on their property, especially when the dangerous condition is readily apparent and beyond the landowner’s control.