Hartel, Administratrix v. Long Island Railroad Co.

1973-12-10

Headline: Court declines to review a railroad employee’s wrongful-death suit, leaving a lower court’s ruling that the railroad was not liable intact and denying a new jury trial for the family.

Holding: The Court denied the petition for review, leaving the lower-court directed verdict for the railroad in place and declining to grant a new trial.

Real World Impact:

Leaves the lower-court ruling for the railroad in place, preventing a new jury trial.
Family’s claim based on prior robberies and union warnings goes unresolved at Supreme Court.
Permits lower courts to exclude evidence of robberies at other stations in similar trials.

Topics: workplace safety, railroad employee death, employer liability, evidence of prior crimes

Summary

Background

A ticket agent who worked for a commuter railroad was killed when he entered a passenger waiting room to open a steel shutter at the Mineola station. There was no peephole in the shutter or door, so the agent could not see the waiting room from his ticket office. The agent’s widow sued under the Federal Employer’s Liability Act, saying the railroad knew of robbery dangers and should have taken safety steps.

Reasoning

At trial the widow tried to show the railroad should have foreseen a holdup by offering evidence of ten robberies or attempts at other nearby stations over four years and union warnings asking for peepholes and silent alarms. The trial judge excluded much of that evidence and granted the railroad a directed verdict — meaning the judge took the case away from the jury and ruled for the railroad. The Supreme Court denied the widow’s petition to review that ruling, so the lower-court result stands without a Supreme Court decision on the facts.

Real world impact

Because the Court refused review, the judge’s ruling for the railroad remains in place and the family does not get a new jury trial from the Supreme Court. The denial is not a final ruling on the legal question nationwide; it leaves the lower-court handling and evidentiary choices intact for this case and similar cases unless later courts say otherwise.

Dissents or concurrances

Justice Douglas, joined by Justice Brennan, dissented: he would have vacated the judgment and sent the case back, saying a jury should decide whether the lack of a peephole and the railroad’s knowledge of robberies made it negligent.