Hennepin County District Court File No. 27-CV-11-14451
SYLLABUS Summary judgment dismissing a claim of violation of the Safety Appliance Act is inappropriate if there is any evidence from which a jury could reasonably conclude that the act was violated and that such violation caused a railroad employee's injury. Summary judgment dismissing a claim of negligence under the Federal Employers' Liability Act is inappropriate if there is any evidence from which a jury could
reasonably conclude that a railroad carrier breached its duty of care and that such breach caused a railroad employee's injury.
The opinion of the court was delivered by: Cleary, Judge
Considered and decided by Hooten, Presiding Judge; Cleary, Judge; and Smith, Judge.
Appellant Sean Gallagher sustained personal injuries while coupling railroad cars for his employer, respondent BNSF Railway Company. He commenced this action, alleging that his injuries resulted from respondent's violation of the Safety Appliance Act (SAA) and negligence under the Federal Employers' Liability Act (FELA). The district court granted summary judgment for respondent, and appellant challenges that decision, asserting that genuine issues of material fact exist as to both claims. We reverse and remand.
This case involves the mechanisms used to couple railroad cars. Each end of a railroad car has a drawbar, which is a metal bar that is fastened to a housing mechanism on the car and extends out from the end of the car. On the end of each drawbar is a knuckle, which is a clamp that is capable of interlocking with another knuckle. In theory, if an open knuckle on one car engages a knuckle on another car when the two cars come together, a pin will drop automatically, locking the two knuckles into place, and the cars will be "coupled." A hump is a man-made hill over which cars are pushed so that they impact cars at the bottom of the hill, or bowl, with enough force to couple automatically. These mechanisms were designed to eliminate the need for railroad employees to go between cars to couple them.
Drawbars are designed to pivot laterally in their cars' housings, which prevents coupled cars from derailing as they move along curved railroad tracks. As a result, a car's drawbar and knuckle may be off-center when the car comes together with a second car, and this misalignment will prevent the two knuckles from engaging and the two cars from coupling. Drawbars must be realigned manually by railroad employees to ensure proper coupling.
On July 24, 2010, appellant was working in respondent's Northtown rail yard. Appellant was checking to ensure that cars had coupled after being pushed over the hump when he noticed that numerous bulkhead flat cars had failed to couple on a curved portion of track. Appellant realigned several drawbars and completed the coupling of a number of cars. He then went between two uncoupled cars and made multiple attempts to get the cars to couple. Appellant claims that, during one of these attempts, he heard and felt a "pop" in his lower back and that he sustained personal injuries. Appellant was eventually able to get the two cars to couple.
Appellant subsequently filed a complaint alleging that he had suffered severe and disabling bodily injuries as a result of respondent's negligence and violation of federal law. Respondent filed a motion for summary judgment, arguing that appellant had failed to set forth any facts upon which respondent might be found negligent and had failed to identify a defect in any railroad equipment that would give rise to liability under federal law. Appellant filed a cross motion for summary judgment on his claim of violation of federal law, arguing that respondent was strictly liable for its cars' malfunctioning coupling mechanisms. Following a hearing, the district court issued an order denying appellant's motion and granting summary judgment for respondent. The court determined that appellant had failed to raise a genuine issue as to whether respondent's equipment had malfunctioned, in violation of federal law, and had failed to raise genuine issues on the elements of breach, causation, and foreseeability for his negligence claim. This appeal followed.
I. Did the district court err by granting summary judgment for respondent on appellant's claim of violation of the SAA?
II. Did the district court err by granting summary judgment for respondent on appellant's claim of ...