Brian Crompton v. BNSF Railway Company
745 F.3d 292
7th Cir.2014Background
- Crompton sued BNSF under FELA and the LIA for injuries from a door-latch defect on a locomotive.
- On April 24, 2011 Crompton was on BNSF 5695, a AC4400 locomotive, when the front cab door unexpectedly opened after he latched it, causing him to fall.
- BNSF moved for summary judgment on both claims; the district court denied and the case went to trial.
- Yancey and Perry testified that similar doors had opened on their locomotives without crew action and that BNSF was aware of the defect.
- Ferry inspected the locomotive post-accident and suggested a latched door would not have opened absent a defect; Maryott testified safety inspections showed no defects in the door or latch.
- The jury found BNSF negligent and Crompton contributorily negligent; 70% fault to BNSF, 30% to Crompton; damages of $1.6 million; BNSF appealed arguing lack of evidence of defect.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for negligence under FELA/LIA | Crompton contends latch defect caused door to open | Crompton never showed a defect; door may have been latched improperly | Sufficiency supports jury verdict; record provides a reasonable basis for defect theory |
Key Cases Cited
- Lavender v. Kurn, 327 U.S. 645 (1946) (limits reweighing jury credibility on appeal; jury inferences favored)
- Ellis v. Union Pac. R.R. Co., 329 U.S. 649 (1947) (choice of conflicting versions for jury; questions for jury)
- Lynch v. Northeast Reg'l Commuter R.R. Corp., 700 F.3d 906 (7th Cir. 2012) (jury may infer employer negligence from circumstantial evidence)
- Wis. Alumni Research Found. v. Xenon Pharm. Inc., 591 F.3d 876 (7th Cir. 2010) (deference to jury’s credibility and inferences)
- Tennant v. Peoria & Pekin Union Ry. Co., 321 U.S. 29 (1944) (verdicts sustained when reasonable inferences support negligence)
- Fulk v. Illinois Cent. R.R. Co., 22 F.3d 120 (7th Cir. 1994) (requires proving elements of negligence with relaxed causation)
- Atchison, Topeka & Santa Fe Ry. Co. v. Buell, 480 U.S. 557 (1987) (liberal interpretation of FELA to effectuate remedial purpose)