District of Columbia v. Moulton

Background

A man was injured after his horse became frightened by a steam roller that the District of Columbia had placed on Park Street while repairing the road. The roller had become disabled and remained on the street, covered with canvas, for about two days before the accident. The plaintiff drove past the roller in daylight, saw it in plain view, and the lower courts had held the District liable for his injuries.

Reasoning

The Court asked whether the city was responsible for keeping the steam roller where it was during lawful street repairs. The opinion explains that a municipality has the right to use and retain equipment needed to repair streets and may keep such machines on the worksite until it is reasonable to remove them. Because the roller was being used for a lawful purpose, was a necessary means, and was plainly visible so the plaintiff had notice, the Court said the facts did not allow a jury to find negligence. The trial court therefore should have directed a verdict for the District rather than submit the question to a jury.

Real world impact

This ruling limits when cities can be held responsible for injuries caused by visible, lawfully placed repair equipment and shifts responsibility toward drivers who see and choose to pass such objects. The opinion also explains that seeing an obstruction in time to avoid it counts as notice, meaning a city meets its duty when a hazard is plainly observable. The Court reversed the lower judgment and instructed the appeals court to order a new trial consistent with this view.