Sheehan v. St. Paul & Duluth Ry. Co.
76 F. 201 (1896) (1896)
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Rule of Law:
A railroad company owes no pre-existing duty to anticipate or keep a lookout for trespassers on its tracks. Its duty of care arises only upon actual discovery of a trespasser in a position of peril, at which point it must make all reasonable efforts to avert injury.
Facts:
- The plaintiff was on the defendant's railroad tracks, a place he was not authorized to be.
- The plaintiff's foot became caught and trapped in a cattle guard on the tracks.
- While trapped, the plaintiff saw one of the defendant's trains approaching.
- The plaintiff yelled and made hand motions to signal the train's engineer.
- The train did not stop in time and struck the plaintiff, causing injury.
Procedural Posture:
- The plaintiff sued the defendant railroad company in federal trial court for negligence.
- At the conclusion of the evidence at trial, the trial court judge directed a verdict for the defendant.
- The plaintiff appealed the directed verdict to the U.S. Circuit Court of Appeals.
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Issue:
Does a railroad company breach a legal duty of care to a trespasser by failing to anticipate their presence on the tracks, or does the duty to avoid injury arise only upon the company's actual discovery of the trespasser in a position of peril?
Opinions:
Majority - Seaman, J.
No, a railroad company does not have a pre-existing duty to anticipate trespassers; its duty arises only upon actual discovery of their peril. A railroad company has the right to a free track and is not bound to any act or service in anticipation of trespassers. A trespasser assumes all risks of the conditions found on the tracks, including the operation of trains. Unlike the high duty of care owed to the public at crossings where their presence is expected, the duty to a trespasser is not pre-existing. The obligation arises only at the moment the company's operatives discover the trespasser's peril. At that point, a negative duty arises to make all reasonable efforts to avert injury. In this case, the evidence, including the plaintiff's own conflicting statements and other witness testimony, shows that the train crew did not discover the plaintiff's peril until the train was within 150-200 feet, which was too close to stop in time, meaning the crew did not breach its duty.
Analysis:
This case establishes and reinforces the 'discovered trespasser' doctrine, which significantly limits the duty of care landowners, particularly railroad companies, owe to individuals unlawfully on their property. By distinguishing this duty from the higher standard of care owed at public crossings, the court sets a high bar for trespasser negligence claims. To succeed, a plaintiff must prove not merely that the defendant could have seen them, but that the defendant's employees actually did see them in peril and then failed to exercise reasonable care. This ruling protects railroads from extensive liability and places the primary assumption of risk on the trespasser.
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