Sheffer v. Springfield Airport Authority

In Sheffer v. Springfield Airport Authority, 261 Ill. App. 3d 151, 154, 632 N.E.2d 1069, 198 Ill. Dec. 458 (1994), Martha Sheffer brought suit against Simmons Airlines, Inc., d/b/a American Eagle (Simmons), after she alighted from a Simmons aircraft and slipped and fell on a patch of ice on her way to the airport terminal. Sheffer, 261 Ill. App. 3d at 151-52. A jury found Simmons liable for Sheffer's injuries. Sheffer, 261 Ill. App. 3d at 151-52. On appeal, the appellate court noted that a common carrier owes its passengers the highest duty of care and that this duty compels the carrier to furnish the passengers an opportunity to safely alight from the conveyance and reach a place of safety. Sheffer, 261 Ill. App. 3d at 154. However, the appellate court also noted that "despite that heightened duty of care, a common carrier has no duty to clean up natural accumulations of snow, ice and water." Sheffer, 261 Ill. App. 3d at 154, citing Shoemaker and Serritos. The appellate court held: "Arguments can be made that a common carrier's duty of highest care should prevail over the natural accumulations rule. However, Serritos and Shoemaker held that the natural accumulations rule should prevail, and we choose to follow those decisions. The natural accumulations rule may be arbitrary in some situations, but overall the certainty involved in a definite rule has been considered to outweigh any possibility of unfairness in unusual situations. We see no reason to place a higher burden on common carriers than on other business entities for clearing natural accumulations of snow, ice or water. Common carriers are charged with the highest duty of care when transporting passengers because passengers must wholly rely upon a common carrier's proper maintenance and safe operation of its equipment during passage. The danger in this case did not arise from any failure by Simmons to maintain or safely operate its equipment; rather, when plaintiff fell on the ice patch on the tarmac, she had as much control over her own safety as if she had been walking across a parking lot. It would be anomalous to impose a duty on Simmons to remove natural accumulations of snow and ice due to its status as a common carrier, but to relieve a mere landowner or business owner from that same duty, and we refuse to do so." Sheffer, 261 Ill. App. 3d at 154-56.