Gallagher v. BNSF Railway Co.
829 N.W.2d 85
Minn. Ct. App.2013Background
- Gallagher sustained injuries while attempting to couple railroad cars in BNSF’s Northtown rail yard on July 24, 2010.
- Plaintiff alleged violations of the Safety Appliance Act (SAA) and negligence under the FELA.
- The district court granted summary judgment for BNSF, denying both claims.
- There was conflicting evidence about whether the equipment malfunctioned or was properly aligned.
- The district court found no actionable defect and no foreseeability of injury; appellate reversal was sought.
- The reviewing court reverses and remands for trial on both the SAA and FELA claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the district court err on the SAA claim? | Gallagher argues evidence raises a SAA violation and causation. | BNSF contends no equipment failure and proper alignment foreclose SAA liability. | Yes; genuine issues of material fact exist |
| Did the district court err on the FELA negligence claim? | Gallagher contends breaches in training, tools, maintenance, and procedures caused injury. | BNSF argues no foreseeable breach or causal link under FELA. | Yes; genuine issues of material fact exist |
Key Cases Cited
- Norfolk & Western Ry. v. Hiles, 516 U.S. 400 (U.S. 1996) (SAA liability when coupling fails to function as required)
- Carter v. Atlanta & St. Andrews Bay Ry., 338 U.S. 430 (U.S. 1949) (SAA violation may be shown by malfunction even if occasional success)
- Myers v. Reading Co., 331 U.S. 477 (U.S. 1947) (SAA violation proof may be based on failure to function properly)
- Gottshall v. Consol. Rail Corp., 512 U.S. 532 (U.S. 1994) (FELA causation is liberal; injury “in whole or in part” due to negligence)
- Urie v. Thompson, 337 U.S. 163 (U.S. 1949) (FELA negligence if carrier knew or should have known standards were inadequate)
- Hoyt Props., Inc. v. Prod. Res. Grp., L.L.C., 736 N.W.2d 313 (Minn. 2007) (summary judgment error when weighing credibility or resolving factual issues)
- DLH, Inc. v. Russ, 566 N.W.2d 60 (Minn. 1997) (summary-judgment limitations; credibility not to be weighed)