Rucker v. RDS Farm Inc
2:15-cv-00272
N.D. Ind.Aug 28, 2017Background
- On June 12, 2013 an Amtrak passenger train struck a farm tractor hauling an anhydrous ammonia tank at a rural Indiana grade crossing; Amtrak engineer William Rucker inhaled ammonia and suffered minor injuries.
- Rucker sued the tractor driver David Allen, RDS Farm, Amtrak (his employer) under FELA and the Locomotive Inspection Act (LIA), and CSX Transportation (owner of the track) under state negligence; Marie Rucker asserted a derivative loss of consortium claim.
- Amtrak and CSX moved for summary judgment on Rucker’s claims against them (including LIA/FELA claims against Amtrak and state claims against CSX), and on Marie Rucker’s derivative claim.
- Key factual disputes narrowed: Amtrak produced evidence that the locomotive had FRA-certified glazing; Rucker produced no evidence that glazing violated LIA standards or caused his injuries; Rucker conceded washer-fluid shortfall did not impair his view or cause the crash.
- CSX produced an INDOT agreement showing federal funds were used to install crossbucks and yield signs at the crossing; CSX also produced evidence a county installed an advanced warning disc sign in 2004; Rucker failed to prove that the trees obstructing view were on CSX’s right-of-way.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Amtrak violated LIA / was negligent under FELA as to cab glazing and crashworthiness | Rucker argues cab glazing/crashworthiness was inadequate and debris/washer-fluid may have impaired view | Amtrak showed FRA-certified glazing, no evidence of noncompliance, and washer-fluid issue did not affect causation | Summary judgment for Amtrak: no LIA violation proven; no FELA negligence shown re: cab condition or washer fluid |
| Whether absence of seat belts/padding supports LIA or FELA claim | Rucker implied claim for missing restraints/padding | Amtrak: regs do not require restraints or padding; no evidence that absence caused injury | Summary judgment for Amtrak: no LIA claim and no causation under FELA |
| Whether state-law challenge to crossing design/warning devices is preempted | Rucker contends crossing was unreasonably hazardous and lacked advanced warning | CSX: FHWA/INDOT-funded improvements were installed per agreement, triggering federal preemption; advanced disc sign not material to preemption and was present | Summary judgment for CSX: federal law preempts state claims attacking adequacy of federally funded warning devices |
| Whether CSX had duty to remove obstructing trees on its right-of-way (obstructed-view claim) | Rucker contends trees near tracks obstructed view and were on CSX right-of-way | CSX: no evidence trees were on its right-of-way; burden on Rucker to produce admissible proof of CSX control | Summary judgment for CSX: Rucker failed to show trees were on CSX right-of-way or causally related |
| Derivative loss of consortium (Marie Rucker) | Loss of consortium based on husband’s tort claims | CSX: derivative claim fails if principal claims fail | Held: Denied as derivative claims dismissed against CSX |
Key Cases Cited
- Waymire v. Norfolk & W. Ry. Co., 218 F.3d 773 (7th Cir.) (FELA’s purpose and duty-to-provide-safe-workplace principles)
- Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burden-shifting and failure-of-proof rule)
- Coffey v. Ne. Ill. Reg’l Commuter R.R. Corp., 479 F.3d 472 (7th Cir.) (LIA violation constitutes negligence per se and relaxed causation under FELA)
- CSX Transp., Inc. v. Easterwood, 507 U.S. 658 (Sup. Ct.) (federal preemption of state tort claims when crossing devices were installed using federal funds)
- Kurns v. R.R. Friction Prods. Corp., 565 U.S. 625 (Sup. Ct.) (LIA occupies field regulating locomotive equipment)