Freed v. Erie Lackawanna Railway Co.

Brief Fact Summary.

Freed (Plaintiff) was struck by a train car operated by Erie Lackawanna Railway Co. (Defendant) and sued over his injuries. Defendant introduced evidence at trial that conflicted with answers it had provided to interrogatories.

Synopsis of Rule of Law.

Answers to interrogatories provided by a party are not binding on that party at trial.

Facts.

Plaintiff was an employee of Defendant, and was struck by a train car being pushed in reverse by an engine. The railway was required to have a lookout on such lead cars when outside of the yard limits. In answer to an interrogatory, Defendant stated that the car that struck Plaintiff was outside the yard limits. Once at trial, Defendant introduced evidence that the car was actually within the yard. A judgment in favor of Defendant resulted and Plaintiff appealed, arguing that Defendant’s answer to the interrogatory should have been binding.

Issue.

Are answers to interrogatories binding upon the responding party at trial?

Held.

(Brooks, J.) No. Answers to interrogatories provided by a party are not binding on that party at trial. Interrogatories are answered at an early stage in a lawsuit when evidence may be incomplete. The answers to interrogatories should be weighed against any conflicting evidence offered at trial. Similarly, if a witness makes a statement in a deposition, that statement may be contradicted at trial and both statements are admissible and should be considered by the factfinder in reaching a decision. Affirmed.

Discussion.

Answers provided to interrogatories are statements of a party and are therefore admissible evidence, but the party is not bound by those statements. Counsel answering interrogatories usually preface the answer with a statement that the answer is given without prejudice to the party’s right to modify the answer should further information come to light.