Mitchell v. Rochester Railway case brief

Mitchell v. Rochester Railway case brief summary
45 N.E. 354 (N.Y. 1896)

CASE SYNOPSIS

Plaintiff tort claimant brought a negligence action against defendant railroad for injuries sustained when she was frightened by the railroad's approaching horses. The railroad appealed an order of the General Term of the Supreme Court in the Fifth Judicial Department (New York), which affirmed an order made on the minutes of the trial judge setting aside a nonsuit and granting a new trial.

CASE FACTS
While the claimant was about to board a car operated by the railroad, an approaching horse car belonging to the railroad frightened her. The fright caused a miscarriage and a consequent illness.

DISCUSSION

• The court reversed the appellate court's affirmance of the grant of a new trial after nonsuit because the claimant was not entitled to recovery from the railroad's negligence. 
• The court held that no recovery was available for mere fright where there was no immediate personal injury and where the resulting miscarriage was not the proximate result of the railroad's negligence. 
• The court found that the injuries were too remote and unforeseeable for recovery, and that the injuries were the result of an accident that was not reasonably anticipated and over which the railroad had no control. 
• The court further found that a nonsuit was appropriate as a matter of law.

CONCLUSION

The court reversed the appellate court's order, which affirmed an order setting aside a nonsuit and granting a new trial in the tort claimant's negligence action. The court affirmed the trial court's nonsuit.

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