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New York Central Railroad v. Grimstad

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

Grimstad (Plaintiff) sued New York Central Railroad (Defendant) when her husband drowned and Defendant had no lifesaving equipment aboard its barge.

Synopsis of Rule of Law.

When the connection between the defendant’s actions and the plaintiff’s injury are too remote or speculative, defendant cannot be held responsible as the but-for cause of the injury.


Grimstad (Plaintiff) was on a barge owned by New York Central Railroad (Defendant). She felt the barge get bumped by a tugboat and ran to the deck. She looked over the side and saw her husband drowning. She looked for a line, but by the time she came back he had drowned. She sued Defendant for failing to provide lifesaving equipment.


Was Defendant’s failure to provide lifesaving equipment the but-for cause of Plaintiff’s husband’s drowning?


No, the Court held that Defendant’s failure to provide lifesaving equipment was not the but-for cause of Plaintiff’s husband’s drowning. The Court reversed the judgment.


The Court stated that it would be impossible to guess whether access to a life buoy would have actually saved the husband. Too many factors would have had to come together (Plaintiff retrieving it quickly, throwing it accurately, and it working) to prevent the drowning. The jury could only speculate. The Court said the trial court should not have denied Defendant’s motion to dismiss.

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