Texas Midland R.R. Co. v. Geraldon
103 Tex. 402, 128 S.W. 611, 1910 Tex. LEXIS 216 (1910)
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Rule of Law:
A property owner's right to exclude others from their premises must be exercised with ordinary care, and the owner may be liable for injuries if they eject a person with knowledge that doing so will subject them to a dangerous condition likely to endanger their health or life.
Facts:
- Mr. Geraldon, his wife, and child arrived at the Enloe train station in the afternoon but missed their intended train.
- The family decided to remain in the station's waiting room until the next train, which was scheduled for 5:00 AM the following morning.
- At approximately 10:00 PM, the railroad's agent informed the family they had to leave because he was closing the station.
- It was raining outside, and Mr. Geraldon informed the agent that his wife was in "no condition to go out into the rain."
- The agent disregarded the warning, insisted the family leave, and threatened to have the town marshal forcibly remove them.
- To avoid being arrested, the family left the station and walked through the rain to find lodging, during which Mrs. Geraldon became soaked.
- Mrs. Geraldon was having her menstrual period, and the exposure to the cold rain caused it to stop, resulting in subsequent physical illness and suffering.
- The next morning at the station, the same agent pointed Mr. Geraldon out to an officer, who publicly searched him for a gun in front of other passengers, causing him mortification.
Procedural Posture:
- Geraldon (plaintiff) sued the railroad company (defendant) in the District Court of Hunt County, a state trial court.
- The case was tried before a jury.
- At trial, the defendant railroad requested a directed verdict in its favor, which the trial court refused.
- The jury returned a verdict for the plaintiff, Geraldon.
- The railroad company appealed the trial court's judgment to the Court of Civil Appeals (an intermediate appellate court), which affirmed the judgment.
- The railroad company then appealed the decision of the Court of Civil Appeals to this court (the state's highest court).
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Issue:
Does a railroad agent act unlawfully by exercising the company's right to close a station and eject waiting passengers when the agent knows that forcing them into inclement weather would likely endanger their health?
Opinions:
Majority - Mr. Justice Brown
Yes. A railroad agent acts unlawfully by ejecting a passenger into dangerous conditions that are likely to harm their health. While a railroad company has the right to close its station at a reasonable hour, this right must be exercised with ordinary care for the safety of those present. The agent was sufficiently notified of Mrs. Geraldon's vulnerable condition, and common humanity forbids exercising a legal right in a manner that would knowingly cause serious injury to another person. The court analogized this situation to the duty not to expel a trespasser from a moving train into a dangerous location and cited the doctrine of necessity, which prioritizes the preservation of human life and health over the strict enforcement of property rights.
Analysis:
This decision establishes that property rights are not absolute and are qualified by a duty of ordinary care toward others on the premises, even those who might otherwise be considered trespassers. It affirms that a property owner can be held liable for foreseeable harm caused by exercising their right to exclude someone under dangerous circumstances. The case is significant for setting a precedent that even a vague warning about a person's health condition can be sufficient to put an owner on notice of their duty of care. This principle limits the right to exclude by balancing it against the fundamental value of protecting human health and safety.
