Pokora v. Wabash Railway Co.

Supreme Court of United States
292 U.S. 98 (1934)

ELI5:

Rule of Law:

The determination of whether a driver's conduct at an obstructed railroad crossing constitutes contributory negligence is a question of fact for the jury, not a question of law for the judge to decide based on a rigid standard of care.

Facts:

John Pokora, an ice dealer, was driving his truck in Springfield, Illinois, and needed to cross four railroad tracks belonging to the Wabash Railway.
Pokora stopped at an ice depot on the northeast corner of the crossing but decided to proceed to another depot on the opposite side.
A string of box cars parked on the first track (a switch track) obstructed his view of the main tracks to the north.
Pokora stopped his truck about ten to fifteen feet from the first track, looked for trains, and listened.
Hearing no bell or whistle, he proceeded to drive across the switch track.
As his truck reached the main track, it was struck by a passenger train coming from the north at a speed of twenty-five to thirty miles per hour, causing him injury.

Procedural Posture:

John Pokora sued Wabash Railway Co. in U.S. District Court (a federal trial court) to recover damages for his injuries.
The District Court directed a verdict for the defendant, Wabash Railway, finding Pokora guilty of contributory negligence as a matter of law.
Pokora, as appellant, appealed to the U.S. Circuit Court of Appeals (an intermediate appellate court).
The Circuit Court of Appeals affirmed the trial court's judgment, with one judge dissenting.
The U.S. Supreme Court granted Pokora's petition for a writ of certiorari.

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Issue:

Is a driver who crosses a railroad track with an obstructed view contributorily negligent as a matter of law for failing to stop, get out of their vehicle, and look for an approaching train?

Opinions:

Majority - Mr. Justice Cardozo

No. A driver's failure to get out of their vehicle to look for a train at an obstructed crossing does not automatically constitute contributory negligence as a matter of law; rather, the standard is what a reasonably prudent person would do under the circumstances, which is a question for the jury. The Court rejected the rigid rule articulated in B. & O. R. Co. v. Goodman, which suggested a driver must get out and look if their view is obstructed. Justice Cardozo reasoned that such a standard is impractical and often dangerous, as the time it takes for a driver to return to their vehicle and start moving could be the exact moment a hidden train arrives. Furthermore, extraordinary precautions that are uncommon in everyday life should not be imposed as inflexible rules of law. In situations where ordinary safeguards fail, the judgment of what constitutes reasonable care is best left to the jury, which can consider all the particular facts and circumstances of the case.

Analysis:

This decision significantly curtailed the precedent set by B. & O. R. Co. v. Goodman, moving tort law away from judge-made, inflexible standards of care toward a more flexible, fact-sensitive 'reasonable person' standard. It reinforced the traditional role of the jury as the primary fact-finder responsible for determining whether a party breached their duty of care. By limiting the Goodman rule, the Court signaled that questions of negligence should generally be decided by juries rather than by judges applying rigid, per se rules, especially in complex or unusual factual scenarios. This approach has had a lasting impact, favoring case-by-case analysis over formulaic determinations of negligence.

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