New York Central R.R. v. Grimstad case brief

New York Central R.R. v. Grimstad case brief summary
264 F. 334 (2d Cir. 1920)

CASE SYNOPSIS

Defendant railroad company challenged the decision of the United States District Court for the Eastern District of New York, which denied defendant's motion to dismiss plaintiff estate's action under the Federal Employers' Liability Act, Comp. St. §§ 8657-8665, to recover damages for the death of plaintiff's decedent, captain of a barge owned by appellant.

CASE FACTS
Plaintiff estate filed an action under the Federal Employers' Liability Act, Comp. St. §§ 8657-8665, to recover damages for the death of plaintiff's decedent, captain of a barge owned by defendant railroad company. The suit claimed negligence for failure to equip the barge with proper life preservers and other necessary and proper appliances, for want of which the decedent, having fallen into the water, was drowned. The jury returned a verdict in plaintiff's favor. Defendant challenged the district court's decision denying defendant's motion to dismiss the complaint at the end of the case.

DISCUSSION

• The court held that that the jury was speculating when it determined that decedent would not have drowned had there been floatation devices available because there were too many other variables. 
• Therefore, defendant's motion to dismiss should have been granted. 
• The judgment was reversed.

CONCLUSION

The court found that defendant railroad company's motion to dismiss the complaint at the end of the trail should have been granted. The evidence did not show that plaintiff estate's decedent would have been saved from drowning had there been a life-buoy on board because multiple factors would still have hindered his rescue.

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