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Duty of care
In tort law, a duty of care is a legal obligation that is imposed
on an individual, requiring adherence to a standard of
reasonable care to avoid careless acts that could foreseeably
harm others, and lead to claim in negligence. It is the first
element that must be established to proceed with an action in
negligence. The claimant must be able to show a duty of care
imposed by law that the defendant has breached. In turn,
breaching a duty may subject an individual to liability. The
duty of care may be imposed by operation of law between
individuals who have no current direct relationship (familial or Usually city government has a duty
contractual or otherwise) but eventually become related in
of care to repair and maintain the
some manner, as defined by common law (meaning case law). sidewalk

Duty of care may be considered a formalisation of the social

contract, the established and implicit responsibilities held by individuals/entities towards others
within society. It is not a requirement that a duty of care be defined by law, though it will often
develop through the jurisprudence of common law.

Development of the general duty of care

At common law, duties were formerly limited to those with whom one was in privity one way or
another, as exemplified by cases like Winterbottom v. Wright (1842). In the early 20th century,
judges began to recognize that the cold realities of the Second Industrial Revolution (in which end
users were frequently several parties removed from the original manufacturer) implied that
enforcing the privity requirement against hapless consumers had harsh results in many product
liability cases. The idea of a general duty of care that runs to all who could be foreseeably affected
by one's conduct (accompanied by the demolishing of the privity barrier) first appeared in the
judgment of William Brett (later Lord Esher), Master of the Rolls, in Heaven v Pender (1883).
Although Brett's formulation was rejected by the rest of the court, similar formulations later
appeared in the landmark U.S. case of MacPherson v. Buick Motor Co. (1916) and, in the UK, in
Donoghue v Stevenson (1932). Both MacPherson and Donoghue were product liability cases, and
both expressly acknowledged and cited Brett's analysis as their inspiration.

Scope
Although the duty of care is easiest to understand in contexts like simple blunt trauma, it is
important to understand that the duty can be still found in situations where plaintiffs and
defendants may be separated by vast distances of space and time.

For instance, an engineer or construction company involved in erecting a building may be

reasonably responsible to tenants inhabiting the building many years in the future. This point is
illustrated by the decision of the South Carolina Supreme Court in Terlinde v. Neely 275 S.C. 395,
271 S.E.2d 768 (1980), later cited by the Supreme Court of Canada in Winnipeg Condominium
Corporation No. 36 v. Bird Construction Co. [1995] 1 S.C.R. 85:

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The plaintiffs, being a member of the class for which the home was constructed, are
entitled to a duty of care in construction commensurate with industry standards. In the
light of the fact that the home was constructed as speculative, the home builder cannot
reasonably argue he envisioned anything but a class of purchasers. By placing this
product into the stream of commerce, the builder owes a duty of care to those who will
use his product, so as to render him accountable for negligent workmanship.

Responsibility
Although the idea of a general duty of care is now widely accepted, there are significant differences
among the common law jurisdictions concerning the specific circumstances under which that duty
of care exists. Obviously, courts cannot impose unlimited liability and hold everyone liable for
everyone else's problems; as Justice Cardozo put it, to rule otherwise would be to expose
defendants "to a liability in an indeterminate amount for an indeterminate time to an
indeterminate class."[1] There must be some reasonable limit to the duty of care; the problem is
where to set that limit.

England
Whether a duty of care exists depends firstly on whether there is an analogous case in which the
Courts have previously held there to exist (or not exist) a duty of care. Situations in which a duty of
care have previously been held to exist include doctor and patient, manufacturer and consumer,[2]
and surveyor and mortgagor.[3] Accordingly, if there is an analogous case on duty of care, the court
will simply apply that case to the facts of the new case without asking itself any normative
questions.[4]

If there is no similar case that the court will determine whether there is a duty of care by applying
the three normative criteria the House of Lords set out in Caparo Industries plc v Dickman.[5] The
criteria are as follows:

Harm must be a "reasonably foreseeable" result of the defendant's conduct;[6][7][8][9]

A relationship of "proximity" must exist between the defendant and the claimant;
It must be "fair, just and reasonable" to impose liability.

European Union

Australia

The High Court of Australia has deviated from the British approach, which still recognises a
proximity element. Rather, Australian law first determines whether the case at hand fits within an
established category of case where a duty of care has been found.[10]: p 217 For example, occupiers
of a premises automatically owe a duty of care to any person on their premises.[11]

If this is not the case, then the plaintiff must prove that it was reasonably foreseeable that harm
could result from the defendant's actions. If so, the Court then applies a "salient features" test to
determine whether the plaintiff is owed a duty of care.[10] Some of the salient features which the
Court considers in making this inquiry include:

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1. Whether imposition of a duty of care would lead to "indeterminate liability" – that is, it
would interfere with the legitimate protection or pursuit of an individual's social or business
interests.[10]: p 219–20
2. Whether imposition of a duty would constitute an unreasonable burden on individual
autonomy.[10]: p 223–5
3. The degree of vulnerability of the plaintiff to the defendant's actions – their ability to guard
against the harm.[10]: p 225–6
4. The degree of knowledge which the defendant had about the probability and likely
magnitude of harm to the plaintiff.[10]: p 230–1

Special rules exist for the establishment of duty of care where the plaintiff suffered mental harm, or
where the defendant is a public authority.[12]

To establish a duty of care, the plaintiff has to satisfy the requirement of CLA Act ss 27–33. In light
of this, a large number of individuals cannot claim injuries as well. Meanwhile, compared to the
"No-Fault Compensation" system in New Zealand, the cost to claim injuries is much higher. In
light of this, individuals especially the victims who lack knowledge or capability may choose not
claim private nuisance after balancing the burden and outcomes. This view affirmed by Regina
Graycar, he states that the courts in Australia are reluctant to award damages for personal
injuries.[13]

In New South Wales, a plaintiff is able to recover for non-economic loss, including pain and
suffering, loss of amenities/expectation of life and disfigurement, upon the severity of the loss
being at least 15% of 'most extreme case'.[14] As of October 2016, NSW Attorney General, Gabrielle
Upton, has updated the maximum amount of damages for non-economic loss from $594,000 to
$605,000.[15]

France

On 27 March 2017, the French National Assembly adopted a law entitled “Devoir de vigilance des
entreprises donneuses d'ordre”,[16] whose title has been translated into English as a "duty of
vigilance" or "duty of care".[17]

The law will oblige large French companies (companies with at least 5,000 staff in France or
10,000 staff within their combined French and foreign offices over two consecutive years) [18] to:

"Establish and implement a diligence plan which should state the measures taken to
identify and prevent the occurrence of human rights and environmental risks resulting
from their activities, the activities of companies they control and the activities of sub-
contractors and suppliers on whom they have a significant influence."[17]

Sweden

Sweden does not have such a law.

Switzerland

In Switzerland, a federal popular initiative named 'For responsible businesses – protecting human
rights and the environment' was launched by a coalition of non-governmental organizations. It
proposed a mechanism of public liability when activities of Swiss multinationals, or their
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subsidiaries, violate internationally recognised human rights

and environmental standards.[19]

On 29 November 2020, the responsible business initiative was

accepted by 51% of voters, but rejected by a majority of
cantons. The failure of the initiative leads to the entry into force
of the legislative counter-project. The latter also introduces
new due diligence obligations. Criminal fines can be imposed Flag (in French) supporting the
for failure to report (but nor for breaches of international responsible business initiative.
law).[19]

United States

Because each of the 50 U.S. states is a separate sovereign free to develop its own tort law under the
Tenth Amendment, there are several tests for finding a duty of care in United States tort law.

Foreseeability test

In several states, like Florida and Massachusetts, the sole test is whether the harm to the plaintiff
from the defendant's actions was foreseeable.[20][21]

Multi-factor test

The Supreme Court of California, in a majority opinion by Justice David Eagleson, criticized the
idea that foreseeability, standing alone, constitutes an adequate basis on which to rest the duty of
care: "Experience has shown that . . . there are clear judicial days on which a court can foresee
forever and thus determine liability but none on which that foresight alone provides a socially and
judicially acceptable limit on recovery of damages."[22]

Drawing upon the work of scholars such as Fowler V. Harper, Fleming James Jr., and William
Prosser, California has developed a complicated balancing test consisting of multiple factors which
must be carefully weighed against one another to determine whether a duty of care exists in a
negligence action.

California Civil Code section 1714 imposes a general duty of ordinary care, which by default
requires all persons to take reasonable measures to prevent harm to others.[23] In the 1968 case of
Rowland v. Christian, the court held that judicial exceptions to this general duty of care should
only be created if clearly justified based on the following public-policy factors:

the foreseeability of harm to the injured party;

the degree of certainty he or she suffered injury;
the closeness of the connection between the defendant's conduct and the injury suffered;
the moral blame attached to the defendant's conduct;
the policy of preventing future harm;
the extent of the burden to the defendant and the consequences to the community of
imposing a duty of care with resulting liability for breach;
and the availability, cost, and prevalence of insurance for the risk involved.[24]

A 1997 case added to this:

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the social utility of the defendant's conduct from which the injury arose.[25]

Contemporary California appellate decisions treat the Rowland decision as the "gold standard" for
determining the existence of a legal duty of care, and generally refer to the criteria for determining
the existence of a legal duty of care as the Rowland factors.[26]

In California, the duty inquiry focuses on the general category of conduct at issue and the range of
foreseeable harm it creates, rather than the specific actions or injuries in each case.[27] Appellate
lawyer Jeffrey Ehrlich persuaded the California Supreme Court to clarify the central importance of
this distinction with its 2011 decision in Cabral v. Ralphs Grocery Co. which requires "no duty"
rulings to be based on categorical public-policy rules that can be applied to a range of cases,
without reference to detailed facts.[28] By requiring courts to apply the Rowland factors at this
high level of factual generality, the Cabral decision preserved the role of juries in determining
whether the defendant breached its duty of care based on the unique circumstances of each
case.[23]

A majority of U.S. states have adopted some kind of multi-factor analysis based on the work of
Prosser and others.[29] Some states simply copied California's factors but modified them, like
Michigan (which deleted the insurance factor and never picked up the social utility factor),[30]
while others developed different lists of factors, such as this one from Tennessee:

the foreseeability of the harm or injury;

the possible magnitude of the potential harm or injury;
the importance or social value of the activity engaged in by the defendant;
the usefulness of the conduct to the defendant;
the feasibility of alternative conduct;
the costs and burdens associated with the alternative conduct;
the relative usefulness of the alternative conduct;
and the relative safety of the alternative conduct.[31]

A 2011 law review article identified 43 states that use a multifactor analysis in 23 various
incarnations; consolidating them together results in a list of 42 different factors used by U.S. courts
to determine whether a duty of care exists.[32]

The Tennessee Court of Appeal has also recently followed the California Supreme Court's lead by
citing Cabral for the proposition that duty determinations must be made at the highest level of
factual generality.[33]

Measurement
Once a duty exists, the plaintiff must show that the defendant breached it. This is generally treated
as the second element of negligence in the United States. Breach involves testing the defendant's
actions against the standard of a reasonable person, which varies depending on the facts of the
case. For example, physicians will be held to reasonable standards for members of their profession,
rather than those of the general public, in negligence actions for medical malpractice.

In turn, once the appropriate standard has been found, the breach is proven when the plaintiff
shows that the defendant's conduct fell below or did not reach the relevant standard of reasonable
care.[34]

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However, it is possible that the defendant took every possible precaution and exceeded what would
have been done by any reasonable person, yet the plaintiff was injured. If that is the case, then as a
matter of law, the duty of care has not been breached and the plaintiff cannot recover in
negligence.[35][36] This is the key difference between negligence and strict liability; if strict liability
attaches to the defendant's conduct, then the plaintiff can recover under that theory regardless of
whatever precautions were taken by the defendant.

Examples

Products

Product liability was the context in which the general duty of care first developed. Manufacturers
owe a duty of care to consumers who ultimately purchase and use the products. In the case of
Donoghue v Stevenson [1932] AC 562 of the House of Lords, Lord Atkin stated:

My Lords, if your Lordships accept the view that this pleading discloses a relevant cause
of action you will be affirming the proposition that by Scots and English law alike a
manufacturer of products, which he sells in such a form as to show that he intends
them to reach the ultimate consumer in the form in which they left him with no
reasonable possibility of intermediate examination, and with the knowledge that the
absence of reasonable care in the preparation or putting up of the products will result in
an injury to the consumer's life or property, owes a duty to the consumer to take that
reasonable care.

Land

At common law, in the case of landowners, the extent of their duty of

care to those who came on their premises varied depending on
whether a person was classified as a trespasser, licensee, or invitee.
This rule was eventually abolished in some common law jurisdictions.
For example, England enacted the Occupiers Liability Act 1957.
Similarly, in the 1968 landmark case of Rowland v. Christian,[24] the
Supreme Court of California replaced the old classifications with a
general duty of care to all persons on one's land, regardless of their
status. After several highly publicized and controversial cases, the
California Legislature enacted a statute in 1985 that partially restored
immunity to landowners from some types of lawsuits from
trespassers.[37]
A notice in the Republic of
Colorado's highest court adopted the Rowland unified duty of care Ireland informing potential
analysis in 1971. The resulting explosion of lawsuits against Colorado entrants on premises of
landowners caused the state legislature to enact the Colorado limits to the duty of care
Premises Liability Act in 1986, which enacted a cleaned-up statutory
version of the common law classifications and simultaneously
expressly displaced all common law remedies against landowners in order to prevent state courts
from again expanding their liability.

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In the Republic of Ireland, under the Occupiers' Liability Act, 1995, the duty of care to trespassers,
visitors and "recreational users" can be restricted by the occupier; provided reasonable notice is
given, for which a prominent notice at the usual entrance to the premises usually suffices.[38]

Business

In business, "the duty of care addresses the attentiveness and prudence of managers in performing
their decision-making and supervisory functions."[39] The "business judgment rule presumes that
directors (and officers) carry out their functions in good faith, after sufficient investigation, and for
acceptable reasons. Unless this presumption is overcome, courts abstain from second-guessing
well-meaning business decisions even when they are flops. This is a risk that shareholders take
when they make a corporate investment."[39]

Cybersecurity

With increased cyber threats and attacks, legislation has evolved to incorporate how to establish
responsibility in the event of a breach. Key terms in privacy bills and laws cite 'reasonable security'
or 'duty of care' as a requirement of organizations when managing sensitive data.[40] If a company
manages private information such as social security numbers (SSN) or personal health information
(PHI), it is their responsibility to practice 'duty of care' and establish 'reasonable controls' to
protect this data. For example, if a hacker group attacks a bank with ransomware, and they
exfiltrate all their client data - who is responsible for potential wire fraud, identity theft, and costs
for litigation? Businesses are required to demonstrate they have implemented a security strategy
based on their risk profile, as it is specific for each working environment. Legislation is outlining
specific roles for executives in order to carry out 'duty of care' properly, as in the case of the
Colorado Privacy Act. It states, "A controller shall take reasonable measures to secure personal
data during both storage and use from unauthorized acquisition. The data security practices must
be appropriate to the volume, scope, and nature of the personal data processed and the nature of
the business."[41] The New York Privacy Act (NYPA)[42] also proposed a 'duty of care' for risk
assessments by controllers regarding personal data.

The common theme in establishing duty of care is the assessment of risk,[43] the likelihood of these
risks occurring, and how they would impact all parties potentially affected by those risks.
Companies must comply with these new requirements of their duty to for reasonable security as it
applies to their working landscape - to manage risk appropriately or be liable for the harm they
could cause.

With compliance requirements of 'reasonable security' to protect data, there is also an increase in
more data breach litigation examining if organizations practiced reasonable and appropriate
security controls. Recent case settlements include Herff Jones (https://ag.ny.gov/sites/default/file
s/nyag_herff_jones_aod_final.pdf) and DNA Diagnostics (https://www.attorneygeneral.gov/wp-c
ontent/uploads/2023/02/2023-02-16-AVC-DNA-Diagnostics-Center.pdf) in which these
organizations must implement an information security program to manage risks based on
documented frameworks such as Duty of Care Risk Analysis (DoCRA), CIS RAM, NIST, ISO
27005, or The Sedona Conference Commentary on a Reasonable Security Test.[44]

See also
Due diligence
Standard of care
Reasonable person

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Duty of Care Risk Analysis (DoCRA) (https://www.docra.org/)

References
1. Ultramares Corporation v. Touche, 255 N.Y. 170, 174 N.E. 441 (1931).
2. Donoghue, infra
3. Smith v Eric S Bush [1990] 1 AC 831
4. Robinson v Chief Constable of West Yorkshire Police [2018] UKSC 4
5. Caparo Industries plc v Dickman [1990] 2 AC 605
6. Donoghue v Stevenson [1932] UKHL 100 (https://www.bailii.org/uk/cases/UKHL/1932/100.ht
ml), [1932] AC 562 (26 May 1932), House of Lords (UK).
7. Wormleaton v Thomas & Coffey Limited (No 4) [2015] NSWSC 260 (http://www.austlii.edu.a
u/au/cases/nsw/NSWSC/2015/260.html), Supreme Court (NSW, Australia).
8. Chapman v Hearse [1961] HCA 46 (http://www.austlii.edu.au/au/cases/cth/HCA/1961/46.htm
l), (1961) 106 CLR 112, High Court (Australia).
9. Endeavour Energy v Precision Helicopters Pty Ltd [2015] NSWSC 169 (http://www.austlii.edu.
au/au/cases/nsw/NSWSC/2015/169.html), Supreme Court (NSW, Australia).
10. Perre v Apand [1999] HCA 36 (http://www.austlii.edu.au/au/cases/cth/HCA/1999/36.html),
(1999) 198 CLR 180, High Court (Australia).
11. Safeway Stores v Zaluzna [1987] HCA 7 (http://www.austlii.edu.au/au/cases/cth/HCA/1987/7.
html), (1987) 162 CLR 479, High Court (Australia).
12. Civil Liability Act 2002 (https://www.austlii.edu.au/au/legis/nsw/consol_act//) (NSW) sections
27–33; 41–45.
13. Regina Graycar, 'Love's Labour's Cost: The High Court Decision in Van Gervan v Fenton'
(1993) 1 Torts Law Journal 122,136.
14. Civil Liability Act 2002 (NSW) s 16 (https://www.austlii.edu.au/au/legis/nsw/consol_act//s16.h
tml)(1).
15. "Civil Liability (Non-economic Loss) Amendment Order 2016 (NSW)" (https://www.legislatio
n.nsw.gov.au/#/view/regulation/2010/606/whole).
16. Entreprises : devoir de vigilance des entreprises donneuses d'ordre (http://www.assemblee-n
ationale.fr/14/dossiers/devoir_vigilance_entreprises_donneuses_ordre.asp), published 28
March 2017
17. Ethical Trading Initiative, France adopts new corporate “duty of care” law (http://www.ethical
trade.org/blog/france-adopts-new-corporate-duty-care-law), 1 March 2017, accessed 7 April
2017
18. Norton Rose Fulbright, A new duty of care for the most significant companies in France (htt
p://www.nortonrosefulbright.com/knowledge/publications/147606/a-new-duty-of-care-for-th
e-most-significant-companies-in-france), accessed 7 April 2017
19. Popular Initiative ‘For responsible businesses – protecting human rights and the
environment’ (https://www.admin.ch/gov/en/start/documentation/votes/20201129/iniziativa-
popolare-per-imprese-responsabili-a-tutela-dell-essere-umano-e-dell-ambiente.html), official
website of the Swiss government, 2020 (page visited on 30 November 2020).
20. McCain v. Florida Power Corp., 593 So. 2d 500, 503 (Fla. 1992).
21. Jupin v. Kask, 849 N.E.2d 829, 835 (Mass. 2006).
22. Thing v. La Chusa, 48 Cal. 3d 644, 667 (http://online.ceb.com/CalCases/C3/48C3d644.htm)
(1989).
23. Cabral v. Ralphs 51 Cal.4th 764 (http://scocal.stanford.edu/opinion/cabral-v-ralphs-grocery-3
3956) (2011)
24. Rowland v. Christian, 69 Cal. 2d 108 (http://online.ceb.com/calcases/C2/69C2d108.htm)
(1968).

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25. Parsons v. Crown Disposal Co., 15 Cal. 4th 456 (http://online.ceb.com/calcases/C4/15C4t456.

htm) (1997).
26. Romero v. Superior Court, 89 Cal.App.4th 1068 (http://law.justia.com/cases/california/caapp4
th/89/1068.html) (2001), quoting, "Juarez v. Boy Scouts of America, Inc." 81 Cal. App. 4th
377 (http://law.justia.com/cases/california/caapp4th/81/377.html) (2000)
27. Ballard v. Aribe, 41 Cal. 3d 564, 572 n.6 (http://online.ceb.com/calcases/C3/41C3d564.htm#
MA000696) (1986). In this oft-cited footnote, the Court stated: "[A] court's task — in
determining 'duty' — is not to decide whether a particular plaintiff's injury was reasonably
foreseeable in light of a particular defendant's conduct, but rather to evaluate more
generally whether the category of negligent conduct at issue is sufficiently likely to result in
the kind of harm experienced that liability may appropriately be imposed on the negligent
party."
28. "Chavez v. Glock, Inc." 207 Cal.App.4th 1283, 1314 (http://www.leagle.com/xmlresult.aspx?x
mldoc=In%20CACO%2020120724024.xml) (2012), citing, "Cabral v. Ralphs" 51 Cal.4th 764,
772 (http://scocal.stanford.edu/opinion/cabral-v-ralphs-grocery-33956) (2011)
29. Adams v. City of Fremont, 68 Cal.App.4th 243 (http://online.ceb.com/calcases/CA4/68CA4t2
43.htm) (1998).
30. Buczkowski v. McKay, 441 Mich. 96, 1100-1101; 490 N.W.2d 330 (1992).
31. McCall v. Wilder, 913 S.W.2d 150, 153 (Tenn. 1995).
32. W. Jonathan Cardi, The Hidden Legacy of Palsgraf: Modern Duty Law in Microcosm, 91
B.U.L. Rev. 1873 (Dec. 2011).
33. "Gregory v. Metropolitan Government of Nashville", 2012 WL 5306196, *10 (http://judicialvie
w.com/State-Cases/tennessee/Government__Politics/Gregory-v-Metropolitan-Government-of
-Nashville-and-Davidson-County/28/565916) (Tenn. Ct. App., 2012)
34. Quelimane Co. v. Stewart Title Guaranty Co., 19 Cal.4th 26 (http://online.ceb.com/CalCases/
C4/19C4t26.htm) (1998).
35. Gilson v. Metropolitan Opera, 5 N.Y.3d 574 (2005).
36. Bozzi v. Nordstrom, Inc., 186 Cal. App. 4th 755 (http://online.ceb.com/calcases/CA4/186CA4t
755.htm) (2010).
37. Calvillo-Silva v. Home Grocery, 19 Cal. 4th 714 (http://online.ceb.com/CalCases/C4/19C4t71
4.htm) (1998).
38. "Occupiers' Liability Act, 1995" (http://www.irishstatutebook.ie/1995/en/act/pub/0010/print.h
tml). Irish Statute Book. Oireachtas. 17 June 1995. Retrieved 2009-10-16.
39. Alan R. Palmiter, Corporations: Examples and Explanations, 5th ed. (New York: Aspen
Publishers, 2006), 192.
40. Johnson, Vincent. "Cybersecurity, Identity Theft, and the Limits of Tort Liability" (https://com
mons.stmarytx.edu/cgi/viewcontent.cgi?article=1417&context=facarticles). Digital Commons
at St. Mary's University.
41. "Colorado Privacy Act" (https://leg.colorado.gov/sites/default/files/2021a_190_signed.pdf)
(PDF). Colorado General Assembly.
42. "PRIVACY TRENDS: FOUR STATE BILLS TO WATCH THAT DIVERGE FROM CALIFORNIA AND
WASHINGTON MODELS" (https://fpf.org/blog/privacy-trends-four-state-bills-to-watch-that-d
iverge-from-california-and-washington-models/). Future of Privacy Forum.
43. "Duty of Care Risk Analysis (DoCRA)" (https://www.docra.org/). The DoCRA Council.
44. "DNA Diagnostics - Assurance of Voluntary Compliance" (https://www.attorneygeneral.gov/
wp-content/uploads/2023/02/2023-02-16-AVC-DNA-Diagnostics-Center.pdf) (PDF). Office of
Attorney General - PA. 2023.

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