Union Stock Yards Co. of Omaha v. Chicago, Burlington
& Quincy R.R. case brief summary
196 U.S. 217 (1905)
CASE FACTS
Plaintiff terminal company argued an entitlement to contribution from defendant railway for damages plaintiff was compelled to pay following injuries sustained by plaintiff's employee. Specifically, plaintiff asserted that defendant's liability stemmed from a defective railway car brake that caused the injury, a defect that could have been discovered by defendant before turning the car over to plaintiff for use by its employee.
DISCUSSION
CONCLUSION
The judgment denying plaintiff terminal company's claim for contribution from defendant railway for injuries sustained by plaintiff's employee was affirmed because both parties were found equally negligent in failing to properly inspect for a defective brake in the railway car turned over to plaintiff by defendant and because the defect was not caused by defendant, which had obtained the car from another company.
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196 U.S. 217 (1905)
CASE SYNOPSIS
Plaintiff terminal company
appealed a judgment of the United States Circuit Court of Appeals for
the Eighth Circuit, which affirmed an order denying plaintiff's claim
for contribution from defendant railway for injuries sustained by
plaintiff's employee.CASE FACTS
Plaintiff terminal company argued an entitlement to contribution from defendant railway for damages plaintiff was compelled to pay following injuries sustained by plaintiff's employee. Specifically, plaintiff asserted that defendant's liability stemmed from a defective railway car brake that caused the injury, a defect that could have been discovered by defendant before turning the car over to plaintiff for use by its employee.
DISCUSSION
- The United States Supreme Court disagreed, upholding the rule that one of several wrongdoers could not recover against another wrongdoer, even if one had been compelled to pay all of the damages for the injury sustained.
- Neither plaintiff nor defendant was primarily responsible for the injuries, the Court explained, as neither party upheld its duty of inspection and the evidence failed to show that the defect was caused by defendant, which had obtained the car from another company.
- Finding both parties equally negligent, the Court refused to carve out an exception to the rule and impose a duty of contribution upon defendant because defendant did not create the dangerous condition from which the injuries resulted.
CONCLUSION
The judgment denying plaintiff terminal company's claim for contribution from defendant railway for injuries sustained by plaintiff's employee was affirmed because both parties were found equally negligent in failing to properly inspect for a defective brake in the railway car turned over to plaintiff by defendant and because the defect was not caused by defendant, which had obtained the car from another company.
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