Earlier this year, the Supreme Court of Virginia issued an opinion in a Virginia train accident case involving an employee who was injured while working for the defendant railroad company. The case required the court to determine if the plaintiff presented sufficient evidence to establish that the defendant’s negligence was the cause of his injuries. Ultimately, the court concluded that the jury’s verdict was supported by some evidence supporting a finding of causation, and the verdict was affirmed.
The Facts of the Case
According to the court’s opinion, the plaintiff worked as a conductor for the defendant railroad. One day, the plaintiff was asked to help make a “cut,” which is when several of the cars in a train are released and left behind. The plaintiff completed the cut without issue; however, as the plaintiff was walking back to a nearby electrical box, he lost contact with the train’s engineer.
Evidently, the train’s engineer became worried after losing contact with the plaintiff and set out to see if anything was wrong. The engineer walked around to the rear of the train, and saw the plaintiff lying at the bottom of a 36-foot embankment. There were no witnesses to the plaintiff’s fall, and the plaintiff had no memory of the accident. The walkway where the plaintiff was when he fell was about 15 inches wide, and the embankment was approximately 70 degrees.
The plaintiff filed a claim against his employer under the Federal Employers’ Liability Act, claiming that the defendant was negligent in providing only a 15-foot walkway. The case proceeded to trial, and the jury found in favor of the plaintiff, issuing a damages award over $300,000. The defendant appealed, arguing that the plaintiff’s circumstantial evidence fell short of what was required to prove his case.
The Court’s Decision
The court held that the evidence presented at least raised the issue of causation, which was sufficient to support the jury’s verdict. The court began by noting that courts treat the issue of proximate cause “leniently” in FELA cases. Thus, a plaintiff bringing a case under FELA must only show that the defendant’s conduct played “even the slightest” role in bringing about their injury.
Here, the court acknowledged that the plaintiff presented no direct evidence of how he fell, and that his case relied entirely on circumstantial evidence. However, the court was explained that direct evidence of causation is not always required. In the end, the court reasoned that the jury could reasonably infer from the evidence presented that the plaintiff fell because the walkway was only 15 inches wide.
Have You Been Injured in a Maryland Workplace Accident?
If you or a loved one works in the railroad industry and have recently been injured on the job, you may be entitled to monetary compensation through a Maryland personal injury lawsuit. At the law firm of Lebowitz & Mzhen, LLC we represent injury victims and their families in personal injury and wrongful death cases across Maryland, Virginia, and Washington, D.C. To learn more about how we can help you pursue a claim for compensation against those responsible for your injuries, call 410-654-3600 today.
More Blog Posts:
Who Is at Fault in Maryland Train Accidents?, Maryland Trucking Accident Lawyer Blog, published February 6, 2019.
Can a Truck Driver’s Employer Be Held Liable in a Maryland Truck Accident?, Maryland Trucking Accident Lawyer Blog, published January 18, 2019.