Train Station Injuries in California

When a passenger is injured in a California train station, does California law impose an extra duty of care on the train station to help prevent the injury?

This is the question the California Court of Appeal answered last week in the case of Churchman v. Bay Area Rapid Transit District.

The question arises in relation to California's Civil Code Section 2100. This statute, known as the "common carrier" statute, applies to trains, cable cars, planes, taxis, buses, and other vehicles which transport passengers for payment. These services are common carriers, and they have a heightened standard of care they owe to their passengers.

Alice Churchman passed through the turnstile in a northern California train station, preparing to get on a Bay Area Rapid Transit train. The train station was noisy, crowded, and somewhat chaotic. This caused her to lose her balance, fall down, and injure herself. She sued the Bay Area Rapid Transit District, alleging negligence and a breach of the common carrier heightened duty of care under California law.

The trial court dismissed her case, and the Court of Appeal affirmed. The Court noted that the common carrier rule does not extend to situations where the person to be transported has not yet boarded the vehicle. Ordinary risks of a busy train platform do not provide the basis for liability for breaching the common carrier duty of care.

There would be exceptions, when, for example, employees of the carrier take responsibility for passengers to guide them towards the vehicle. The carrier establishes carrier-passenger relationship that triggers the heightened duty of care, which continues until the passenger has been safely discharged. But absent the carrier-passenger relationship, no liability will attach.

Los Angeles and Southern California have multiple train stations where common carriers and the carrier-passenger relationship are formed. Nevertheless, it's important to note that the relationship only begins once passengers board the vehicle or are escorted to it by employees of the transportation service.

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