Pratt v. National Railroad Passenger Corp.
709 F. App'x 33
| 2d Cir. | 2017Background
- Decedent Eric J. Pratt (15) was struck and killed by an Amtrak train in Vernon, Vermont on January 15, 2012.
- Plaintiff Michael J. Pratt, administrator of the estate, sued Amtrak and related defendants for wrongful death alleging negligence (speed, horn use, failure to brake).
- Defendants produced objective evidence: train video and onboard data reports (speed, horn, brake events) and expert analysis of braking effects.
- District court granted summary judgment for defendants, concluding objective evidence resolved contrary eyewitness testimony and that even earlier emergency braking would not have prevented the collision.
- Second Circuit reviewed de novo and affirmed the district court's grant of summary judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Train speed and horn blasts (credibility of eyewitnesses) | Video/data had inconsistencies; eyewitness testimony contradicted defendants’ evidence | Objective video and data reliably show speed and horn before impact; minor formatting differences explained by software versions | Court: Objective evidence resolved disputes under Scott v. Harris; no genuine issue of fact on speed/horn |
| Whether horn sounded before impact | Horn stopped at collision per video; thus horn may not have warned decedent | Both video and data indicate horn sounded before and during collision | Court: Both sources show horn before impact; horn warning established |
| Whether engineer should have applied emergency brakes earlier | Earlier braking would have prevented death; eyewitness/lay testimony implies more time | Engineer reasonably could not brake earlier than ~3 seconds before impact; defense expert showed 3s braking slowed train ~2 mph and delayed arrival only hundredths of a second | Court: No reasonable juror could find earlier braking would have avoided collision; causation not established |
| Causation for any alleged breach | Any breach (speed, horn, brakes) caused death; jury should decide | Even if breach, it was not the proximate cause because earlier braking would not have changed outcome | Court: As a matter of law, breach did not cause death; summary judgment for defendants affirmed |
Key Cases Cited
- Scott v. Harris, 550 U.S. 372 (2007) (objective video evidence can resolve credibility disputes on summary judgment)
- Andrews v. Metro-N. Commuter R.R. Co., 882 F.2d 705 (2d Cir. 1989) (open-run rule: engineer who gives a proper alarm may assume a pedestrian will heed it)
- Raspente v. Nat’l R.R. Passenger Corp., 111 F.3d 239 (2d Cir. 1997) (applies open-run rule under New York law)
- Minda v. United States, 851 F.3d 231 (2d Cir. 2017) (summary judgment review standard)