Baltimore & Ohio Railroad v. Goodman

Background

A widow and the administrator of Nathan Goodman sued a railroad after Goodman was killed when a train struck his truck at a grade crossing. The railroad argued Goodman’s own carelessness caused the crash. At trial the railroad asked the judge to direct a verdict for it, but the request was refused, and the jury returned a verdict for the widow. A federal appeals court affirmed that judgment before the case reached this Court.

Reasoning

Goodman was driving east and a train ran southwest across the road at not less than sixty miles an hour. Evidence showed the rail line was straight, the crossing was in daylight, and Goodman knew the crossing. He had limited view near a section house and slowed from ten or twelve miles per hour to five or six near the crossing. The Court said a person who goes onto railroad tracks must expect danger if a train arrives and must stop or even exit the vehicle if unsure whether a train is near. Relying only on not hearing a train or a signal is at the traveler’s risk. The Court concluded that, given the clear standard of conduct here, the driver’s own negligence was established and the verdict for the widow could not stand.

Real world impact

The decision reverses the jury’s verdict and relieves the railroad of liability in this case. It signals that courts may decide similar crossing cases as a matter of law when a driver’s failure to stop or take simple precautions is obvious, rather than leaving the issue to juries.