Atlantic Coast Line Railroad v. Driggers

Background

A railroad brakeman who had worked about five years was injured and died after stepping off the footboard of a moving switch engine and striking a passing passenger train. The worker’s estate sued the railroad under the Federal Employers Liability Act. A jury found for the estate, and South Carolina’s highest court affirmed. The railroad asked the Supreme Court to review whether the evidence was legally sufficient to show its negligence caused the death.

Reasoning

The Court looked at the facts: the crew regularly used a nearby spur; the conductor opened the switch and went to look for a train; the brakeman stood on the right footboard facing south; the conductor signaled about an approaching passenger train; the brakeman nodded but did not look back, and he then stepped off between the northbound and southbound tracks. The passenger train on the southbound line had a clear right of way, had sounded signals, and was visible to its engineer. The Court concluded the brakeman’s sudden action was the sole and direct cause of his death, and that the railroad had no duty that, if breached, proximately caused the injury.

Real world impact

Because the Court found the employee’s own negligence was the direct cause, the jury should have been instructed to find for the railroad, and the judgment for the estate was reversed and the case remanded to South Carolina’s courts for further proceedings consistent with this opinion. This decision turns on the specific facts about the worker’s conduct and the train’s clear right of way.