Sheehan v. St. Paul & Duluth Ry. Co

Brief Fact Summary. The Plaintiff, Sheehan (Plaintiff), was trespassing upon the Defendant, St. Paul & Duluth Ry. Co.’s (Defendant) railway, when Plaintiff’s foot became stuck. Defendant’s train crew did not see Plaintiff until it was too late to stop the train and Plaintiff was injured.

Synopsis of Rule of Law. Railroad companies are under a constant and strict duty of care to individuals at railway crossings, but are not bound to any act or service in anticipation of trespassers at other points along the track.

Facts. The Plaintiff was walking on the Defendant’s railroad track when his foot slipped and became caught on the rail. As Defendant’s train approached, Plaintiff was unable to extricate his foot. Defendant’s train crew did not see Plaintiff until it was too late to stop the train and therefore Defendant’s train ran over Plaintiff’s foot. The trial court entered a directed verdict for Defendant and Plaintiff appeals.

Issue. Is a railroad company under a duty to anticipate trespassers upon its tracks, such that it will be liable for injuries that occur thereon?

Held. No. Judgment affirmed.
* Defendant was neither a passenger on the train nor crossing at a public crossway at the time of his injury. Therefore, Defendant was a trespasser. The railroad company is obligated to exercise some degree of care for trespassers upon its property and will be liable if the trespasser is wantonly injured in the operation of the railroad.
* Because of the hazardous nature of railroad operation, railroad companies are held to a duty of constant and strict care in relation to individuals at a street crossings or other places where the railroad is on notice that individuals cross. However, at all other points along a railroad track the railroad company has a right to a free track and is not bound to anticipate trespassers. Trespassers at these points assume all risks of condition that may be found there.
* The obligation of the railroad company to a trespasser arises at the moment of the trespasser’s discovery and is a duty to make all reasonable efforts to avert injury. The Defendant’s train crew made sufficient efforts to avert injury in the present case.

Discussion. The constant and strict care standard that arises at railroad crossings is described as a positive duty, while the duty to avert injury to discovered trespassers is a negative duty.