Great Northern Railway Co. v. Wiles

Background

A father, acting as administrator of his son’s estate, sued a railroad under a federal employers’ liability law after the son, a freight brakeman named Dennis E. Wiles, was killed when a passenger train ran into the rear of his freight train. The freight train had broken in two when a drawbar pulled out; the separated rear portion stopped on a dark, misty night around a sharp curve. The passenger train, unaware of the stopped freight cars, struck the rear end within a few minutes. The trial jury awarded damages, but the defendant railroad won judgment notwithstanding the verdict; the State Supreme Court reversed and ordered judgment on the verdict.

Reasoning

The Court examined whether the railroad’s negligence could be inferred from the drawbar’s failure and how the deceased’s own conduct affected recovery. Company safety rules required trainmen to go back immediately and give stop signals, torpedoes, or fusees to protect a stopped train from being overtaken. Evidence showed Wiles knew the passenger train’s schedule, was signaled to protect the rear, and failed to go back or place warning devices. The Court said the case could not be resolved simply by inferring negligence from the broken drawbar. It emphasized that there was no excuse for Wiles’ clear, simple duty to protect the rear of his train and that his neglect caused the collision.

Real world impact

The Court reversed the State Supreme Court’s judgment and sent the case back for further proceedings consistent with this opinion. The decision stresses that railroad employees must follow emergency rules and that equipment failure alone does not automatically prove carrier fault when the crew clearly neglected protective duties. It warns against excusing obvious neglect, which could endanger passengers and increase liability for railroads.