Haynes v. New York Central Railroad Co., 204 N.Y. 303 (1912)

A railroad company can be found negligent for operating its train at an excessive speed through a suburban area with frequent crossings and pedestrian traffic, creating an unreasonable risk of harm to others lawfully using the public highway.

Summary

This case concerns a fatal accident where the plaintiff’s intestate was struck by a train while crossing a public highway. The court addressed whether the railroad company was negligent in operating its train at a high speed in a suburban area and whether the deceased was contributorily negligent. The Court of Appeals held that it was a question for the jury whether the railroad’s speed constituted negligence, given the location and likelihood of pedestrian traffic. The court also found that the deceased’s contributory negligence was a question for the jury, considering the information he had about the approaching train.

Facts

The deceased visited a hotel located near a double-track electric railroad on a public highway. He inquired about the next train to Schenectady and was told it would arrive in about ten minutes. The deceased walked onto the hotel piazza. A limited, or express, train traveling at 45-50 mph struck him as he crossed the tracks. The accident occurred near a designated stop for local trains, close to an intersecting highway and several houses. The conductor saw the deceased when the train was 50 feet away. The train blew its whistle 500-600 feet from the crossing and attempted to brake and reverse, but was unable to stop in time.

Procedural History

The trial court granted a nonsuit, effectively dismissing the plaintiff’s case. The appellate division affirmed. The New York Court of Appeals granted leave to appeal. The Court of Appeals reversed the lower courts’ decisions, ordering a new trial.

Issue(s)

1. Whether the defendant railroad company was negligent in operating its train at a speed of 45-50 mph in the described suburban location, creating an unreasonable risk of harm to pedestrians crossing the tracks.

2. Whether the plaintiff’s intestate was contributorily negligent as a matter of law in attempting to cross the tracks, given his knowledge of the approaching train and the circumstances of the crossing.

Holding

1. Yes, because given the combination of conditions, the location on a much-traveled road near an intersecting highway and several houses, it was within the province of a jury to determine if running the train at 45-50 mph constituted negligence.

2. No, because based on the information available to the deceased regarding the approaching train (believing it to be a local), it cannot be held as a matter of law that he was contributorily negligent in attempting to cross the tracks.

Court’s Reasoning

The Court reasoned that while such speed might not be negligent in a rural area, the present location was an ordinary suburban road in a thickly settled neighborhood. The railroad was bound to run its cars with due regard for the safety of others lawfully using the public highway. The court emphasized that the degree of care should be measured by the dangers to be apprehended. Considering the possibility of people crossing to reach the intersecting highway, hotel, private houses, or the local train stop, the jury should decide if the train’s speed was negligent. Regarding contributory negligence, the Court acknowledged that less evidence is required in death cases. Given the deceased’s understanding that a train was due in ten minutes, and the inference that he thought it was a local train that would stop, it was reasonable for him to attempt to cross. The Court stated, “Ordinarily, if a person attempts to cross a railroad track after satisfying himself by the exercise of ordinary care that it is a prudent thing to do, he cannot be charged with contributory negligence as matter of law for not again looking in a particular direction.” The Court held that, in view of the circumstances, it could not be held as a matter of law that the deceased was contributorily negligent.