Duty of Care in Streetlight Maintenance: Clay Electric Case
School
University of Akron**We aren't endorsed by this school
Course
3300 MISC
Subject
Law
Date
Dec 11, 2024
Pages
1
Uploaded by runninggirl1998
Case Brief: Clay Electric Cooperative, Inc. v. JohnsonIssueDoes a company that undertakes the maintenance of streetlights owe a duty of careto third parties, such as pedestrians, to prevent harm caused by its failure to maintain the lights properly?RuleNegligence requires four elements: duty, breach, causation, and damages. Under Florida law, the principle of duty may arise from legislative enactments, judicial precedent, or the general facts of the case. The "undertaker's doctrine" establishes that one who undertakes to provide a service assumes a duty to act with reasonablecare. (Restatement (Second) of Torts § 324A).ApplicationDutyClay Electric contracted with the Jacksonville Electric Authority to maintain streetlights in a residential area. The Florida Supreme Court determined that this undertaking created a legal duty to pedestrians in the area, as proper lighting was necessary for their safety. By agreeing to maintain the lights, Clay Electric assumed a duty to act with reasonable care to avoid creating risks for pedestrians.BreachClay Electric failed to implement basic maintenance procedures, such as inspecting streetlights regularly. At the time of the incident, the light nearest the site of the accident had been nonfunctional for a significant period. This lack of care constituted a breach of its duty to maintain the lights in working condition.Causation:Actual Cause: The inoperative streetlight rendered the roadway dark, which prevented the driver from seeing Dante Johnson in time to avoid hitting him.Proximate Cause: The harm was foreseeable, as inadequate streetlight maintenance increased the risk of such accidents in the area.DamagesThe damages were evident: the death of a minor pedestrian. The plaintiff, Dante’s estate, sought compensation for wrongful death, including emotional and economic losses.ConclusionThe Florida Supreme Court held that Clay Electric owed a duty of care under the "undertaker's doctrine" and that its failure to maintain the streetlights constituted a breach. The breach was a proximate cause of Dante Johnson’s death. The court reversed the lower court's summary judgment and allowed the case to proceed.Citation:Clay Elec. Coop., Inc. v. Johnson, 873 So. 2d 1182, 1184-86 (Fla. 2003).
