Lafflin v. Buffalo & S.W.R. Co., 106 N.Y. 136 (1887)
A railroad company is not negligent simply because there is a space between a train platform and a station platform, if that space is a necessary result of the practical operation of the railroad and not excessively wide, especially if the area is well-lit and the condition has been safely used for a significant period.
Summary
Lafflin sued the railroad for negligence after she stepped into the gap between the train and station platforms. The Court of Appeals reversed a judgment in her favor, holding that the existence of a necessary gap, that wasn’t excessively wide and which had been safely used by thousands of passengers over several years, did not constitute negligence. The court emphasized that the plaintiff failed to prove the gap was wider than necessary, or that the railroad failed to take proper precautions.
Facts
The plaintiff, Lafflin, was a passenger on the defendant’s railroad. As she was exiting the train at the Grand Street station, she stepped into the space between the car platform and the station platform, resulting in injuries. The station was located on a curve, creating an unavoidable gap. The plaintiff claimed the gap was wider than usual. The defendant had been using the same configuration for six years, during which thousands of passengers had safely traversed the gap.
Procedural History
The plaintiff won a jury verdict at trial. The defendant appealed. The General Term affirmed the judgment. The Court of Appeals granted the defendant’s motion for review and reversed the lower court’s ruling.
Issue(s)
Whether the railroad company was negligent in maintaining a platform with a space between it and the train car, when that space was a necessary result of the railroad’s operation and had been safely used for an extended period.
Holding
No, because the existence of a necessary gap of reasonable width, in an area safely used for years, does not constitute negligence without proof of excessiveness or failure to take proper safety precautions.
Court’s Reasoning
The court reasoned that some opening between the car and the platform was necessary for the safe operation of the railroad, especially on a curved track. The court emphasized that the evidence showed the track and platform at Grand Street had been unchanged for six years, during which thousands of passengers had safely stepped across the opening. The court stated, “For six years prior to the plaintiff’s injury, these openings had proved to be safe and not at all dangerous. Whatever was the width at Grand street, thousands upon thousands of passengers, often in a hurry and thronging in crowds, had stepped over it without harm or danger.” The court found that the plaintiff failed to prove the opening was wider than necessary or that the railroad failed to take proper precautions. The court also noted that the plaintiff’s claim that the gap was unusually wide was based on speculation and contradicted by other evidence. The court highlighted the undisputed evidence showing the railroad came as close to the platform as was safe and prudent. Because of the curve, the gap at the end could not be any smaller. The court concluded that the trial court erred in allowing the jury to find that an eight-inch opening was negligent, given the uncontradicted evidence showing the necessity of such an opening for the safe operation of the trains. Therefore, a new trial was ordered.