Walker v. CSX Transportation, Inc.
2011 U.S. App. LEXIS 17452
| 11th Cir. | 2011Background
- Walker, a Exel employee, was injured in July 2005 while unloading mayonnaise from a railcar with bulkhead doors.
- The bulkhead doors divide the car into three compartments; doors are held by locking pins that retract when a release latch is operated.
- Palettes shifted during transit; when unloading side compartments, the doors’ locking pins jammed and then released, causing the doors to rush forward.
- Walker and a coworker were struck; Walker suffered severe injuries requiring extensive medical care.
- Walker sued CSX and Norfolk Southern in federal court under Georgia negligence law, alleging failure to inspect and maintain the door’s locking system, and seeking damages.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was proximate causation shown for negligent maintenance? | Walker argues neglect to inspect/maintain caused the injury via a defective door. | Defendants contend no evidence that omissions proximately caused Walker's injury. | Proximate causation not shown; omissions not a legal cause of injury. |
| Do privately established AAR rules create a triable issue for negligence? | AAR rules required annual inspections; violations could illustrate negligence. | Privately created rules are illustrative; not negligence per se without causation. | Even assuming negligence, no triable issue because no link to the injury. |
Key Cases Cited
- Anderson v. Barrow Cnty., 256 Ga. App. 160, 568 S.E.2d 68 ( ga. app. 2002) (proximate cause required for actionable negligence)
- Davis v. Aiken, 111 Ga. App. 505, 142 S.E.2d 112 (ga. app. 1965) (negligence actionable only if proximate cause shown)
- Booth v. Quality Carriers, Inc., 276 Ga. App. 406, 623 S.E.2d 244 (ga. app. 2005) (negligence elements; proximate cause essential)
- Davis, 142 S.E.2d at 117-18, 142 S.E.2d 112 (1965) (instruction on proving defective condition and discovery)
- Atlanta Gas Light Co. v. Gresham, 394 S.E.2d 345 (ga. 1990) (proximate cause analysis involves policy and precedent)
- United States v. Four Parcels of Real Prop., 941 F.2d 1428 (11th Cir. 1991) (summary judgment standard; essential elements must be shown)
- McAuley v. Wills, 303 S.E.2d 258 (ga. 1983) (proximate cause and duty analysis in torts)