Justia Transportation Law Opinion Summaries

Defendant performed occasional maintenance and repairs for a fleet of plaintiff's delivery trucks. Defendant usually provided service onsite at plaintiff's plant, but sometimes would take trucks to its shop. In 2007, defendant's employee caused a fatal traffic accident while driving plaintiff's tractor-trailer to defendant's shop for service. The district court concluded that under Illinois law only plaintiff's insurance policy provided coverage for the accident. The Seventh Circuit affirmed. Both insurers provide coverage: defendant's policy by its plain language and plaintiff's policy operation of Illinois public policy. Plaintiff and its insurer are, however, ultimately responsible for the settlement amount. Under Illinois law the vehicle owner's policy is primary over the operator's policy unless a statute provides otherwise. The Illinois tow-truck insurance statute does not apply to provide an exception. View "Coca Cola Ente., Inc. v. ATS Enter., Inc." on Justia Law

Hernandez caused a severe auto accident that closed northbound I-57 for several hours. With traffic not moving, four hours later, a truck rear-ended plaintiff's vehicle, more than four miles away, killing one occupant and seriously injuring his brother. Among others, plaintiff brought a personal-injury suit against Hernandez and related entities on the theory that Hernandez proximately caused the second accident. The district court entered summary judgment for Hernandez and the other defendants. The Seventh Circuit affirmed. There was a four-hour, four-mile gap and the truck driver's behavior was remarkably different than that of other drivers who approached stopped traffic. View "Blood v. VH-1 Music First" on Justia Law

Following a 2007 train derailment and three-day fire that allegedly exposed a small Ohio town to cancer-causing agents, plaintiffs sought damages on behalf of a putative class. Plaintiffs' expert testified that the normal background level of dioxin is four parts per trillion and that the range within area homes was from 11.7 to 274 ppt. A doctor testified about increased risk of cancer. The district court granted summary judgment for the train company, finding that plaintiffs had not established general or specific causation and, as a matter of law, any increased risk of cancer or other diseases was too insignificant to warrant the court's ordering a lengthy period of medical monitoring. The Sixth Circuit affirmed, noting the absence of conclusive medical evidence that plaintiffs faced even a one-in-a-million increased risk of cancer. View "Hirsch v. CSX Transp., Inc." on Justia Law

This negligence suit under Georgia law stemmed from an injury plaintiff suffered as he unloaded freight from a railcar in July 2005. On appeal, plaintiff asserted that the district court erred by granting summary judgment to defendants because there were triable issues as to whether defendants were negligent in failing to regularly inspect or maintain the bulkhead door. The court held that the district court was correct in granting defendants summary judgment where plaintiff presented no evidence from which a jury could infer that defendants' omissions, even if negligent, were a proximate cause of his injury, an essential element of his negligence claim under Georgia law. Accordingly, the judgment of the district court was affirmed. View "Walker, et al. v. CSX Transportation, Inc., et al." on Justia Law

This case arose when an ocean-going tanker collided with a barge that was being towed on the Mississippi River, which resulted in the barge splitting in half and spilling its cargo of oil into the river. Following the filing of numerous lawsuits, including personal injury claims by the crew members and class actions by fishermen, the primary insurer filed an interpleader action, depositing its policy limits with the court. At issue was the allocations of the interpleader funds as well as the district court's finding that the maritime insurance policy's liability limit included defense costs. The court affirmed the district court's decision that defense costs eroded policy limits but was persuaded that its orders allocating court-held funds among claimants were tentative and produced no appealable order. View "Gabarick, et al. v. Laurin Maritime (America) Inc., et al." on Justia Law

This case arose from an oil spill in the Mississippi River when an ocean-going tanker struck a barge that was being towed. Appellants (Excess Insurers) appealed the district court's decision requiring them to pay prejudgment interest on the funds deposited into the court's registry in an interpleader action. The Excess Insurers argued that the district court erred by: (1) finding that coverage under the excess policy was triggered by the primary insurer's filing of an interpleader complaint; (2) holding that a marine insurer that filed an interpleader action and deposited the policy limits with the court was obligated to pay legal interest in excess of the policy limits; and (3) applying the incorrect interest rate and awarding interest from the incorrect date. The court held that because the Excess Insurers' liability had not been triggered at the time the Excess Insurers filed their interpleader complaint, the district court erred in finding that they unreasonably delayed in depositing the policy limit into the court's registry and holding them liable for prejudgment interest. Therefore, the court reversed the judgment and did not reach the remaining issues. View "Gabarick, et al. v. Laurin Maritime (America), Inc., et al." on Justia Law

A semi-truck jackknifed while making a delivery for a federally licensed carrier and struck a vehicle, killing its driver. The estate brought a wrongful death action in Illinois state court against the driver, his wife (titular owner of the truck), and the company. The suit settled with entry of a $2 million consent judgment against the company, the driver, and his wife. The estate agreed that payment by the company's carrier of the $1 million policy limit would satisfy part of the judgment; the remainder would come from the driver's policy for "Non-trucking/bobtail liability" that covers driving cabs without trailers outside the service of the federally licensed carriers under whose authority drivers operate. That carrier declined coverage, citing a policy exclusion for vehicles "while in the business of anyone to whom ... rented," and obtained summary judgment in federal district court. The Seventh Circuit affirmed, citing 49 C.F.R. 376.2(d)(2), which defines "owner" as including someone like the driver, "who, without title, has the right to exclusive use of equipment" and reasoned that the driver, as agent for his wife, leased the truck to the company, even though the company was unaware that the wife held title. View "Clarendon Nat'l Ins. v. Medina" on Justia Law

Plaintiff was unloading a railway tank car filled with sulfuric acid when its chemical contents exploded, spraying across his face and chest and inflicting severe burns. He sought damages under the common law, but the district court held that his lawsuit was preempted by the Hazardous Materials Transportation Act, 49 U.S.C. 5101–5128. The Third Circuit affirmed. The Act expressly preempts any common law requirement about the design of a package, container, or packaging component qualified for use in transporting hazardous materials in commerce. The tank car at issue is a container qualified for such use, regardless of whether what plaintiff was doing constituted transport or his employment status at the precise moment of his injury. View "Roth v. Noralfco, LLC" on Justia Law

This case concerned the standard of causation applicable in cases arising under the Federal Employers' Liability Act ("FELA"), 45 U.S.C. 51 et seq., which rendered railroads liable for employees' injuries or deaths "resulting in whole or in part from [carrier] negligence." Respondent, a locomotive engineer with petitioner, an interstate railroad, sustained a debilitating hand injury and subsequently filed suit under the FELA. At issue was whether the causation instruction endorsed by the Seventh Circuit was proper in FELA cases where that instruction did not include the term "proximate cause," but did tell the jury defendant's negligence must "pla[y] a part-no matter how small-in bringing about the [plaintiff's] injury." In accord with the text and purpose of the Act, the Court's decision in Rogers v. Missouri Pacific R. Co., and the uniform view of federal appellate courts, the Court held that the Act did not incorporate "proximate cause" standards developed in nonstatutory common law tort actions. The Court held that the charge proper in FELA cases simply tracked the language Congress employed, informing juries that a defendant railroad caused or contributed to a plaintiff employee's injury if the railroad's negligence played any part in bringing about the injury. Accordingly, the judgment of the Seventh Circuit was affirmed. View "CSX Transp., Inc. v. McBride" on Justia Law