Hoffman v. Northeast Illinois Regional Commuter Railroad Corporation, 99 N.E.3d 16

On June 8, 2013, Metra ticket agent Richard Davis stepped backward on the Fox Lake station platform without looking, bumped into Robert Hoffman, who fell and later was diagnosed with a fractured right hip.
Hoffman sued Metra for negligence; Metra pleaded contributory negligence.
At trial Hoffman introduced Metra’s internal safety rules (including a rule to "look before you step") and relied on treating surgeon Dr. Basran’s testimony that Hoffman's hardware was migrating and he would likely need future arthroplasty.
The jury awarded $500,000 in damages (including $70,000 for future medical expenses) but found Hoffman 50% at fault, reducing recoverable damages to $250,000.
Metra moved posttrial for a new trial arguing improper admission of internal safety rules, or alternatively for remittitur of future medical expenses; the trial court denied the motion.
On appeal the First District affirmed, rejecting both grounds for relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admission of Metra internal safety rules	Rules are admissible as evidence that employee violated safety practices and support negligence inference	Admission was improper because internal rules govern employees only and a violation alone does not establish negligence or duty; admission was prejudicial under Evid. R. 403	Court affirmed admission (no abuse of discretion). Internal rules may be considered with other evidence; even if erroneous, any error was harmless on these facts.
Sufficiency of evidence for future medical expenses / remittitur	Testimony and records (past bills, life expectancy, Dr. Basran’s opinion that arthroplasty "will" be needed) supported $70,000 future-medical award	No reliable evidence of projected costs; award excessive and required remittitur	Court held jury award fell within reasonable range given permanent injury, progressive hardware migration, and doctor’s opinion that future surgery was required; no remittitur.

Morton v. City of Chicago, 286 Ill. App. 3d 444 (internal-rule violation alone does not prove willful and wanton conduct)
Luss v. Village of Forest Park, 377 Ill. App. 3d 318 (internal-guideline violation does not, by itself, impose legal duty or defeat summary judgment)
Bulger v. Chicago Transit Authority, 345 Ill. App. 3d 103 (post-accident remedial measures generally inadmissible; exceptions analyzed)
Hudson v. City of Chicago, 378 Ill. App. 3d 373 (violation of internal rule may be considered as some evidence of negligence when combined with other evidence)
Diaz v. Legat Architects, Inc., 397 Ill. App. 3d 13 (trial court abused discretion when remittitur of future medical expenses was granted where evidence supported long-term costs)
Ready v. United/Goedecke Servs., Inc., 238 Ill. 2d 582 (harmless-error standard for evidentiary rulings)