Krywin v. Chicago Transit Authority

Summary

The Illinois Supreme Court considered whether the Chicago Transit Authority breached its heightened common-carrier duty to provide a passenger with a safe place to alight from a train. The court held that the natural-accumulation rule applied to the ice and snow on the platform, so the CTA had no duty to remove or warn about the natural accumulation. It therefore upheld the directed verdict in favor of the CTA.

Holdings

1. The natural accumulation rule applies to the CTA, and the CTA had no duty to remove natural accumulations of snow and ice from its train platform or to warn passengers about those accumulations.
2. Krywin failed to prove that the CTA could have fulfilled its duty to provide a safe place to alight by discharging her under the canopy or elsewhere. The trial court therefore should have directed a verdict for the CTA on the alleged safe-place-to-alight duty.
3. The CTA could not be held liable for the alleged willful and wanton conduct because it owed no duty to remove natural accumulations of ice and snow or to warn of those conditions.

Questions Presented

1. Whether the natural accumulation rule relieved the CTA of a duty to remove or warn about natural accumulations of snow and ice on its train platform despite the common carrier's duty to provide passengers a safe place to alight.
2. Whether Krywin proved that the CTA breached its duty to provide a safe place to alight by allowing her to exit onto an icy portion of the platform rather than under the canopy or at another safer location.
3. Whether the natural accumulation rule relieved the CTA of liability for alleged willful and wanton conduct based on its failure to remove ice and snow or spread sand.

Disposition

affirmed