Lillie v. Thompson

Background

A 22-year-old telegraph operator said her employer required her to work alone overnight in a small, isolated office in the railroad yards in Memphis. The employer knew the yards were frequented by dangerous people but did not light, guard, or patrol the building. Her job meant admitting railroad workers who came at irregular hours and, because there were no windows in the door, she had to open it to identify them. Around 1:30 a.m. she opened the door, a nonemployee forced his way in, and he beat her with a large iron, causing serious, permanent injuries. The trial court dismissed her complaint and granted summary judgment for the railroad, and the appeals court affirmed without opinion.

Reasoning

The central question was whether the facts alleged could support a finding that the injury was at least partly caused by the employer’s negligence. The Court said the complaint, if proved, alleges that the railroad knew of conditions creating a strong likelihood of the exact kind of harm that occurred. The Court explained that it does not matter that the attack was intentional or criminal; an employer still has a duty to take reasonable steps to guard against foreseeable dangers. Because a breach of that duty would be negligence, the Court concluded it could not say as a matter of law that the injury did not result at least in part from the employer’s failure to protect the worker.

Real world impact

The Court reversed the dismissal and sent the case back so a jury can decide if the facts prove employer negligence. The decision means employees who work alone in known-dangerous places may be able to take their claims to a jury rather than being dismissed at the pleading stage. This is not a final finding of liability; the outcome still depends on the evidence at trial.