Ryals v. United States Steel Corp.
Alabama Supreme Court
562 So.2d 192 (1990)
Wilson Ryals, Jr. (plaintiff) and his brother David went to a U.S. Steel Corporation (U.S. Steel) (defendant) electrical substation to strip out copper, brass, and other metals for sale, entering through an open gate despite a surrounding chain-link fence topped with barbed wire and at least one warning sign about the electrical danger. David contacted a 44,000-volt electrified line, suffered third-degree burns over 95 percent of his body, and died days later. Wilson, as administrator of David's estate, sued U.S. Steel for negligently and wantonly failing to secure the substation; after voluntarily dismissing the negligence claim, the trial court granted summary judgment to U.S. Steel on the remaining wantonness claim, and Wilson appealed, arguing evidence that U.S. Steel knew of two prior fatal contacts with the lines supported an inference of wantonness.
Whether the standard of care that a landowner owes to a trespasser intending to commit a criminal act is not to intentionally injure the trespasser.