Torts
793 N.E.2d 1225 (Ind. Ct. App. 2003)
Study notes for Baker v. Fenneman & Brown Properties, LLC: professor notes, cold call prep, exam angles, and memory aids.
A business has a duty to take reasonable action to aid or protect a business invitee who becomes ill or is injured on its premises, regardless of causation.
In Baker v. Fenneman & Brown Properties, the Indiana Court of Appeals addresses the duty of care owed by businesses to their invitees. The court emphasizes that a business must take reasonable steps to assist those injured or in distress on its premises, highlighting the importance of public safety and the responsibility that comes with operating a commercial establishment. This case sets a precedent that the obligation to aid extends beyond proximate cause, implying that businesses can be liable despite not instigating the medical emergency.
Furthermore, the court's reasoning reflects a societal expectation that businesses maintain a safe environment and be proactive in addressing emergencies, which is vital for the protection of patrons. Professors often highlight the implications of this decision on future tort claims and how it establishes a broader interpretation of duty of care in various private and commercial contexts.
CARE - Commercial establishments are Required to Aid all patients in Emergencies.
| Case | Distinction |
|---|---|
| Duncan v. TCI Cablevision of Missouri, Inc. | In Duncan, the court ruled that the business was not liable for injuries caused by the actions of third parties, emphasizing a limited duty of care compared to the broad obligation in Baker. |
| Hoffman v. Board of Education | Hoffman explored the duty of care in educational settings, where the court held that teachers have a heightened duty to protect students, as opposed to the more general duty seen in Baker. |
| Pope v. New Jersey Transit | In Pope, the court found a lack of duty in a case where the victim's injuries were self-inflicted, which contrasts with Baker’s affirmation of duty to aid regardless of causation. |
This rule supports a societal expectation that businesses prioritize public safety and protect their customers, fostering a safe environment and encouraging prompt assistance in emergencies.
Critics may argue that imposing such a duty could lead to an overwhelming liability for businesses, potentially deterring them from operating or complicating emergency situations where professional medical assistance may be required.
This case may be presented in exams focusing on premises liability and the duty of care owed to invitees, testing students on the implications of duty beyond causation. Examinees could be asked to analyze the reasonableness of a business’s response to emergencies.