Baltimore and Ohio R.R. v. Goodman

Supreme Court of United States
275 U.S. 66, 48 S.Ct. 24, 72 L.Ed. 167 (1927)

ELI5:

Rule of Law:

A driver of a vehicle approaching a railroad grade crossing with an obstructed view has a strict duty to stop, look, and listen, and if necessary, to get out of the vehicle to ascertain whether a train is approaching before proceeding.

Facts:

Nathan Goodman was driving an automobile truck in an easterly direction during daylight hours.
He was approaching a railroad crossing with which he was familiar.
Goodman's view of the train tracks to the north was obstructed by a section house until he was approximately twenty feet from the first rail.
Goodman slowed his truck from ten or twelve miles per hour to five or six miles per hour as he neared the crossing, but he did not stop.
A train traveling at least sixty miles per hour struck Goodman's truck at the crossing, killing him.

Procedural Posture:

Nathan Goodman's widow, as administratrix of his estate, sued the Baltimore & Ohio Railroad Co. in a federal trial court for wrongful death.
At trial, the railroad's motion for a directed verdict was denied.
The jury returned a verdict for the plaintiff, and the trial court entered a judgment against the railroad.
The railroad (appellant) appealed the judgment to the U.S. Circuit Court of Appeals.
The Circuit Court of Appeals (appellee being Goodman's estate) affirmed the trial court's judgment.
The railroad then petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.

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Issue:

Does a driver approaching a railroad crossing with an obstructed view have a duty, as a matter of law, to stop and, if necessary, exit the vehicle to ensure it is safe to cross, such that failure to do so constitutes contributory negligence?

Opinions:

Majority - Mr. Justice Holmes

Yes. A driver who cannot be sure whether a train is dangerously near a crossing must stop and, if necessary, get out of the vehicle to check. When a person approaches a railroad track, they enter a known zone of danger and are responsible for their own safety. A driver must stop for the train, not the other way around. Relying on hearing alone is insufficient; if a driver cannot see, they proceed at their own risk without taking further precautions. While the question of due care is generally left to a jury, when a standard of conduct is clear, it should be established as a rule of law by the courts. Goodman's failure to stop and ensure the way was clear was his own fault, and he was therefore responsible for his own death.

Analysis:

This decision establishes a rigid and specific standard of care for drivers at railroad crossings, often referred to as the 'stop, look, and listen' or 'get out and look' rule. It is significant for removing the determination of negligence from the jury in these specific factual circumstances and making it a question of law for the judge to decide. This ruling created a clear, albeit harsh, judicial standard that placed the entire burden of safety on the driver. The precedent set by this case was later famously criticized and softened by Justice Cardozo in Pokora v. Wabash Ry. Co., which returned the question of a driver's reasonable care to the jury.

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