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New York Central R.R. v. Grimstad

Citation. 264 F. 334 (2nd Cir. 1920)
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Brief Fact Summary.

Angell Grimstad was the captain of the barge Grayton, which was owned by the defendant railroad company. The defendant failed to outfit the barge with the proper emergency equipment, including life-preservers, and Angell Grimstad fell into the water and drowned.

Synopsis of Rule of Law.

Jury conjecture or speculation is not enough to determine proximate cause when other factors could have contributed to the injury.


Angell Grimstad, the decedent, was the captain of the barge Grayton, which was owned by the defendant railroad company. The barge was lying on the port side of a steamer in Brooklyn and was carrying sugar from Havana to St. John, N.B. A tugboat bumped against the barge, knocking the decedent overboard. The decedent did not know how to swim, so his wife ran into the barge’s cabin for a small line, but he had disappeared underwater by the time she came back. There were no proper life-preservers on board.


Did the defendant’s negligence in failing to have proper life buoys on the barge cause the plaintiff’s injury?


No. There is no reason to believe that a life buoy would have saved the life of the decedent. The judgement was reversed.


The court determines that a life-preserver (life vest) would have been no use to the decedent here but that the charge covers life buoys as well. The proximate cause of the injury was the decedent falling into the water, and this seemed to have happened with no negligence on the part of the defendant. The court believes that the question of whether a life buoy would have prevented drowning is pure conjecture on the part of the jury. There is no reason to believe with certainty that a life buoy would have made a difference in this situation, as too much was left to chance—his wife might not have gotten it in time, he might not have been able to seize it, and it might not have prevented the drowning at all.

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