Baltimore & Ohio R. Co. v. Goodman

Tort

Baltimore & Ohio R. Co. v. Goodman

Baltimore & Ohio R. Co. v. Goodman

Baltimore & Ohio R. Co. v. Goodman, 275 US 66 (1927).

 

Facts: Goodman was struck and killed by one of Baltimore & Ohio railroad’s (D) trains as he was driving across a railroad crossing. Goodman’s view of the crossing was blocked and he did not stop, look, or listen for approaching trains.

Plaintiff was driving his automobile truck and was killed by a train operated by Defendant running at a rate of speed not less than sixty miles per hour. Plaintiff’s estate argued that he had no practical view beyond a section house until he was about twenty feet from the rail, or twelve feet from danger. Defendant’s engine was obscured by said section house. Plaintiff had been driving at ten or twelve miles per hour, but slowed down to five or six miles per hour as he neared the crossing. The railroad line was straight, it was daylight, and Plaintiff was familiar with the crossing. Plaintiff brought suit against Defendant. Defendant argued that Plaintiff’s own negligence caused his death. Defendant requested a directed verdict, however it was denied. The jury found for the Plaintiff. This decision was affirmed by the Circuit Court of Appeals. Defendant appealed

 

Goodman’s widow (P) sued and the railroad moved for a directed verdict on the grounds that Goodman’s death was the consequence of his own negligence. The trial court entered judgment in favor of Goodman, the court of appeals affirmed, and D appealed.

 

Issues:

1) Can a party prevail on a negligence claim if the evidence shows that that party failed to take reasonable precautions to guard against a risk that he was aware of?

2) In an action for negligence, is the question of due care a matter for the finder of fact to decide when it can be resolved by a clear standard of conduct?

 

Holding and Rule:

1) No. A directed verdict should be entered against a party who has suffered injury because he failed to take reasonable precautions to guard against a known risk. The court held that Goodman was contributorily negligent for not stopping and looking. No reasonable jury could have found in favor of P under these facts.

 

2) Normally the question of due care is left to the finder of fact but when the standard of conduct is clear it should be laid by the courts.

 

Disposition: Reversed.

Notes: The basis of the court’s decision here is contributory negligence. The finder of fact normally determines the applicable standard of care unless the standard is clear. Under the old common law contributory negligence was a complete bar to recovery. Contributory negligence is conduct that falls below the standards established by law for self protection.

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