Wednesday, December 18, 2013

Cleghorn v. New York Central & H. River Ry. Co. case brief

Cleghorn v. New York Central & H. River Ry. Co. case brief summary
56 N.Y. 44 (1874)


CASE SYNOPSIS
Defendant appealed the decision of the General Term in the Fourth Judicial Department (New York) affirming a judgment in favor of plaintiff and affirming an order denying defendant's motion for a new trial in an action to recover for injuries alleged to have been caused by defendant's negligence.

CASE FACTS
Plaintiff was a passenger on defendant's railroad and was injured when a switchman's error caused two trains to collide. The evidence showed that the switchman was intoxicated at the time of the accident and that he had intemperate habits of which defendant was aware. Judgment was entered in favor of plaintiff and punitive damages were awarded. Defendant appealed.

DISCUSSION

  • The court reversed because, although defendant was clearly liable for damages related to plaintiff's injuries, the jury was not properly charged regarding its ability to award punitive damages. 
  • The jury could only properly award punitive damages if it found that defendant's conduct in hiring and retaining switchman as an employee constituted gross misconduct.
  • Because the jury instructions did not clearly indicate that punitive damages could only be awarded if defendant 's behavior constituted gross misconduct, the jury may have awarded the damages without this necessary finding, and reversal was required.

CONCLUSION
Judgment reversed because, although defendant was liable for plaintiff's injuries, the jury instructions did not clearly indicate that punitive damages could only be awarded if defendant 's behavior constituted gross misconduct, thus the jury may have awarded punitive damages without this necessary finding, so reversal was required.

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