Chicago & Northwestern Railway Co. v. United States

Background

The United States sued a railroad company under an 1900 law that forbids keeping animals on interstate trains longer than thirty-six hours without unloading for rest, water, and feeding. The carrier admitted the animals were confined longer than thirty-six hours. The animals were loaded at Bingsted, Iowa, 438 miles from the Union Stock Yards in Chicago on October 4. The car left Clinton, Iowa, on October 5. Near Chicago a drawbar failed at Proviso and derailed a car, causing a delay of two hours and fifty-two minutes; later an air hose burst at Brighton Park, causing twenty-eight minutes more delay. The car reached the stock yards at 9:05 A.M. on October 6, about thirty-nine hours after loading. A jury was instructed on a broad definition of 'due diligence' and found against the railroad.

Reasoning

The Court examined whether the carrier was excused when unloading was prevented by accident or other unavoidable causes and what the statute means by 'due diligence.' The trial court’s instruction told jurors due diligence meant doing whatever human ingenuity could devise, which the Court found too exacting and misleading. The Court said the statute does not require carriers to guarantee arrival times or control train schedules; instead it requires ordinary care, prudence, and reasonable foresight by experienced railroad operators. If, in the exercise of ordinary care, the carrier reasonably expects the car to reach destination within the time limit, it may start transit, and reasonable precautions must be used to avoid or overcome delays. If an unforeseeable storm or accident prevents unloading despite such care, a reasonable delay is excused.

Real world impact

The Court reversed the conviction and sent the case back for further proceedings under correct jury instructions. Railroads and juries must apply an ordinary-care standard, not a requirement to prevent every conceivable delay, when deciding liability for prolonged animal confinement.