Stewart v. Motts
539 Pa. 596, 654 A.2d 535 (1995)

  • Stewart went to Motts’ car repair shop and offered to help repair a gas tank. Stewart ended up getting burned in a gasoline fire. He sued.
  • The Trial Court found for Motts. Stewart appealed
    • Motts successfully argued that gasoline is inherently dangerous, and Stewart knew the risks when he offered to help.
    • The Trial Court found that although Motts owed Stewart the legal duty to provide reasonable care. But even when taking reasonable care, sometimes people get hurt by dangerous substances.
  • The Appellate Court affirmed.
    • The Appellate Court found that reasonable care is always required, but the care that is “reasonable” varies with the danger involved in the act and is proportionate to it.
      • Basically, different situations require different levels of care, but the level of care required is also what would be reasonable for the particular set of circumstances.
    • However, accidents occur even when reasonable care is taken. The Court found that courts shouldn’t require a higher standard of care beyond “reasonable.”
  • This ruling represents the majority view of what level of care is required. However, other courts have found differently.
    • For example, in Wood v. Groh (269 Kan. 420, 7 P.3d 1163 (2000)), the Kansas Supreme Court found that extraordinary care is required when the danger is great.