Robinson v. CSX Transportation, Inc.
103 So. 3d 1006
| Fla. Dist. Ct. App. | 2012Background
- Robinson, lead conductor, was performing a shoving movement with a sixteen-car train through a public crossing when a tractor-trailer failed to stop and collided with the train, injuring him.
- Robinson sued CSX under FELA, alleging CSX failed to provide a safe workplace by not supplying backup safety equipment (backup hose or shoving platform) on the day of the accident.
- The trial court granted CSX’s motion in limine to preclude evidence about the safety equipment.
- Robinson testified he requested a backup hose, while others testified such equipment was regularly used; the court still excluded evidence because none of Robinson’s witnesses showed it was routinely used at that yard that day.
- CSX introduced Robinson’s post-accident accident report, which stated fault on the truck driver and noted Robinson answered 'no' to having a safe workplace, with the term 'shoving platform' redacted by court order in limine.
- During cross-examination, CSX used the redacted report to impeach; Robinson moved to admit the redacted portion for fairness, which the court denied, and the jury returned a verdict for CSX.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether excluding safety-tool evidence was an abuse of discretion | Robinson argues tools were relevant to CSX’s duty to provide a safe workplace. | CSX contends no routine availability was proven; evidence was not probative. | Yes; exclusion was an abuse of discretion. |
| Whether redacted accident report impeachment was proper | Robinson should have been allowed to introduce the redacted portions for completeness. | Redaction kept the focus on driver fault and avoided prejudice. | Yes; error in depriving completeness and fairness. |
Key Cases Cited
- Health First, Inc. v. Cataldo, 92 So.3d 859 (Fla. 5th DCA 2012) (abuse of discretion standard for evidentiary rulings)
- Johannessen v. Gulf Trading & Transp. Co., 633 F.2d 653 (2d Cir.1980) (jury's role in FELA cases is liberal)
- Eggert v. Norfolk & W. Ry. Co., 538 F.2d 509 (2d Cir.1976) (FELA remedial nature and jury consideration of negligence)
- Rogers v. Missouri Pac. R.R. Co., 352 U.S. 500 (1957) (FELA claims submitted to jury when proof justifies)