Globe Malleable & Steel Co. v. New York Central & Hudson River Railroad
227 N.Y. 58 (1919)
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Rule of Law:
A steam railway operating tracks across public streets has a duty to make reasonable use of its rights, which, in an emergency involving a known public hazard like a serious fire, requires it to temporarily yield its right of way and manage its trains to avoid unreasonably obstructing emergency responders when doing so increases the public hazard and leads to greater damage.
Facts:
- On June 23, 1912, at 4:50 a.m., a fire broke out in the Globe Malleable Iron and Steel Company's plant in Syracuse.
- A 2,160-foot long freight train of the West Shore Railroad Company was approaching the area from the west, whose fireman discovered the fire from two miles away and whose engineer, Johnson, was familiar with the general situation and communicating streets.
- Syracuse fire department hose carts, with gongs clanging, responded, attempting to reach the fire via Beach street, Teall avenue, and Greenway avenue, which were crucial north-south thoroughfares.
- The West Shore Railroad's train blocked the Beach Street crossing, forcing the first hose cart to detour over fields; the train subsequently blocked the Teall Avenue crossing.
- As the train approached and then blocked the Greenway Avenue crossing, despite signals from another freight train, shouts from a fire captain, and the train's ability to stop within 30-40 feet or clear the crossing by cutting the train in two minutes, the engineer continued slowly.
- The train's obstruction of the Greenway Avenue crossing caused a 15-minute delay for the fire department, resulting in much greater damage to the Globe Malleable Iron and Steel Company's plant.
Procedural Posture:
- The Globe Malleable Iron and Steel Company (plaintiff) initiated an action for damages against the West Shore Railroad Company (defendant) in a Trial Term court.
- The Trial Term rendered a judgment (impliedly in favor of the plaintiff, as it was subsequently affirmed by the Court of Appeals).
- The West Shore Railroad Company (defendant/appellant) appealed the Trial Term's judgment to the Appellate Division.
- The Appellate Division reversed the Trial Term's judgment and dismissed the plaintiff's complaint, concluding that the complaint should be dismissed as a matter of law.
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Issue:
Does a railway company operating a train across city streets owe a duty to yield the right of way and take reasonable steps to avoid obstructing the passage of emergency vehicles responding to a known, serious fire, such that its failure to do so could constitute negligence?
Opinions:
Majority - Andrews, J.
Yes, a railway company operating a train across city streets owes a duty to yield the right of way and take reasonable steps to avoid obstructing the passage of emergency vehicles in such circumstances. The court held that while railways have a right of way, this right is not absolute and may be temporarily reversed in an emergency to prevent unreasonable impairment of street uses and increased public hazard. A railway must make 'fair use of its tracks in view of its own interests and those of the public.' The jury could reasonably find that the defendant's servants knew or should have known of the serious fire, the fire department's need for haste, and their likely route to the fire. Given that the train could have stopped within forty feet or been cut to clear a crossing in two minutes, the question of whether the defendant made 'reasonable use of its rights in view of the situation which confronted it' was a question of fact for the jury to decide. Therefore, the Appellate Division erred in dismissing the complaint as a matter of law.
Concurring - Hiscock, Ch. J.
Concurring for reversal but voting for a new trial on the ground that errors were committed in rulings on the evidence.
Dissenting - McLaughlin, J.
Dissenting.
Analysis:
This case establishes an important precedent regarding the duty of railway companies to prioritize public safety, particularly in emergency situations. It clarifies that a railway's right of way is not absolute and must yield to the pressing needs of emergency responders when there is knowledge of a public hazard. The ruling underscores the jury's role in determining reasonableness and negligence in such complex factual scenarios, preventing courts from summarily dismissing cases where conflicting inferences could be drawn. This decision strengthens the legal basis for holding infrastructure operators accountable for actions that impede emergency services, potentially influencing future cases involving other forms of transportation or critical infrastructure during crises.
