Justia Transportation Law Opinion Summaries

Deborah Bradshaw and Chrystal Antao sued American Airlines and Mesa Airlines, alleging injuries and damages from the airlines' negligent handling of an in-flight emergency. During a June 2020 flight, the aircraft experienced a malfunction that led to a loss of cabin pressure, requiring an emergency descent. The plaintiffs claimed the pilot failed to properly inform passengers of the threat and descended too rapidly, while American Airlines failed to provide medical personnel upon landing.The case was initially filed in the District Court of Tulsa County, Oklahoma, and later removed to the United States District Court for the Northern District of Oklahoma on diversity grounds. The district court granted summary judgment in favor of the airlines, concluding that federal law preempted Oklahoma's common-carrier standard of care in aviation safety. The court allowed the plaintiffs to pursue a state negligence claim using the federal "reckless-or-careless manner" standard but found no evidence that the airlines violated this standard.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court's decision, holding that the Federal Aviation Act and related regulations preempt state law in the field of aviation safety. The court agreed that the federal "careless or reckless manner" standard of care applies, preempting Oklahoma's common-carrier standard. The court found no genuine issue of material fact regarding a violation of federal regulations by the airlines and upheld the summary judgment in favor of the defendants. View "Bradshaw v. American Airlines" on Justia Law

Eason Propane, LLC, purchased a new Freightliner propane delivery truck, which caught fire due to Empire Truck Sales, LLC's negligence during repairs. The fire caused significant damage to the truck, leading to extensive business losses for Eason Propane. Eason Propane sued Empire, seeking damages for the truck's diminished value, repair costs, lost profits, and other consequential damages.The case was tried in the Lamar County Circuit Court, where the jury found Empire liable and awarded Eason Propane $263,443.39 in damages. Empire moved for a new trial on damages or a remittitur, arguing that the jury's award was against the overwhelming weight of the evidence. The trial court denied Empire's motion, leading to this appeal.The Supreme Court of Mississippi reviewed the case and affirmed the trial court's decision. The court held that the jury's damages award was not manifestly unjust or so excessive as to shock the conscience. The court found that the evidence presented at trial supported the jury's findings, including the testimony of Eason Propane's experts regarding the truck's diminished value and lost profits. The court emphasized that it was within the jury's purview to weigh the credibility of the competing testimonies and evidence.The court concluded that the trial court did not abuse its discretion in denying Empire's motion for a new trial or remittitur. The jury's award of $112,698.46 for the truck's diminished value, $24,744.93 for repair costs, $120,000 for lost profits, and $6,000 for other consequential damages was affirmed. View "Stribling Equipment, LLC v. Eason Propane, LLC" on Justia Law

In August 2014, a train operated by BNSF Railway Company collided with a pickup truck driven by Paul Watson at a railroad crossing in Pawnee County, Oklahoma. Watson, who was not wearing a seatbelt, died instantly, while his wife Terri and their minor child, both belted, survived with injuries. Terri Watson, on behalf of herself, her child, and as a representative of her deceased husband's estate, filed a wrongful death and personal injury lawsuit against BNSF, alleging negligent maintenance of the crossing and failure to install adequate safety features.The case went to trial, and after three weeks of testimony and evidence, the jury found in favor of BNSF on all claims. The plaintiffs' motion for a new trial was denied by the trial court. On appeal, the Court of Civil Appeals, Division IV, found prejudicial errors in the jury instructions, specifically noting that the instructions were biased in favor of BNSF and required an excessive degree of care from Watson. The appellate court reversed the trial court's decision and remanded the case for a new trial.The Supreme Court of the State of Oklahoma reviewed the case on certiorari. The court found that the jury instructions, when considered as a whole, were not so prejudicial as to mislead the jury. The court noted that the instructions accurately reflected Oklahoma law and did not impose a higher standard of care on Watson than required. Consequently, the Supreme Court vacated the opinion of the Court of Civil Appeals, affirmed the trial court's judgment, and reinstated the jury's verdict in favor of BNSF. The case was remanded for further proceedings consistent with this opinion. View "WATSON v. BNSF RAILWAY COMPANY" on Justia Law

Scott Lupia, a locomotive engineer for New Jersey Transit Rail Operations, Inc. (NJT), was injured when the air conditioning (A/C) unit in his cab malfunctioned, causing the temperature to rise to 114 degrees Fahrenheit. Despite notifying his supervisors, Lupia was instructed to operate the train, leading to his collapse from heat exhaustion and subsequent permanent injuries. Lupia filed a lawsuit under the Federal Employers’ Liability Act (FELA), alleging that NJT violated the Locomotive Inspection Act (LIA) by failing to maintain the locomotive's parts and appurtenances, including the A/C unit, in safe operating condition.The United States District Court for the Southern District of New York denied NJT's motion for summary judgment, holding that a temperature control system, including an A/C unit, is considered a "part and appurtenance" of a locomotive under the LIA. The court found sufficient evidence that NJT's failure to maintain the A/C unit in proper condition posed an unnecessary danger of personal injury. During the trial, the court allowed Lupia to introduce a report to impeach NJT’s witness and permitted arguments regarding noneconomic damages. The jury awarded Lupia significant damages for lost earnings and pain and suffering.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the District Court's judgment. The appellate court agreed that a temperature control system is an integral part of a locomotive and that NJT was required to maintain the A/C unit in safe operating condition once it chose to use it as part of its temperature control system. The court also found no abuse of discretion in the District Court's evidentiary rulings and its decision to allow arguments on noneconomic damages. View "Lupia v. New Jersey Transit Rail Operations, Inc." on Justia Law

This case involves a vehicular collision that occurred in a construction zone on Interstate 10 in LaPlace, Louisiana. The plaintiff, Frank Cushenberry, was driving a commercial vehicle when he collided with a truck owned by Barber Brothers Contracting Company, LLC. The truck was partially in the right lane of the highway while backing up to move traffic cones. The collision resulted in significant injuries to Mr. Cushenberry, including a traumatic brain injury.The case was initially heard in a lower court, where the jury found Barber Brothers 100% at fault for the accident and awarded substantial damages to Mr. Cushenberry, his wife, and their two minor children. Barber Brothers appealed the decision, arguing that the trial court erred in its jury instructions and that the jury erred in finding Barber Brothers solely at fault.The Supreme Court of Louisiana found that the trial court did err in its jury instructions, but that this error was not reversible. The court also found that the jury erred in finding Barber Brothers solely at fault for the accident. The court determined that Barber Brothers was 80% at fault and Mr. Cushenberry was 20% at fault.The court also found that the jury abused its discretion in awarding general damages of $10,750,000.00 to Mr. Cushenberry, and loss of consortium damages of $2,500,000.00 to his spouse, Robin Cushenberry, and $1,500,000.00 to each of their minor children. The court reduced these awards to $5,000,000.00 in general damages to Mr. Cushenberry, and loss of consortium damages of $400,000.00 to Mrs. Cushenberry and $100,000.00 to each child.As amended, the trial court judgment was affirmed. View "BARBER BROTHERS CONTRACTING COMPANY, LLC VS. CAPITOL CITY PRODUCE COMPANY, LLC" on Justia Law

The case involves a products liability action against American Honda Motor Co., Inc. (Honda) for an alleged negligent design of a seat-belt system in a 2011 Honda Odyssey. The plaintiff, Sarah Milburn, was severely injured in a car accident while riding in an Uber vehicle, a 2011 Honda Odyssey. Milburn was seated in the third-row middle seat, which had a ceiling-mounted detachable Type 2 anchor system for the seat belt. Milburn fastened her seat belt incorrectly, leaving her lap unbelted. The accident resulted in Milburn becoming a quadriplegic.The trial court rendered judgment in favor of Milburn based on the jury's verdict, and the court of appeals affirmed. The court of appeals held that legally sufficient evidence supported the jury’s findings that the presumption of nonliability applied and that the presumption was rebutted.The Supreme Court of Texas reversed the court of appeals’ judgment. The court held that the presumption of nonliability applied as a matter of law because the 2011 Odyssey’s design complied with mandatory federal safety standards that were applicable to the Odyssey at the time of manufacture and governed the product risk that allegedly caused harm. The court further held that the presumption was not rebutted, as no evidence supports the jury’s finding that the federal safety standards failed to adequately protect the public from unreasonable risks of injury. Therefore, the court rendered a take-nothing judgment for Honda. View "AMERICAN HONDA MOTOR CO., INC. v. MILBURN" on Justia Law

Jacob Marion, a minor, was struck and injured by a train operated by Grand Trunk Western Railroad Company while he was walking down the railroad tracks listening to music. The train's conductor and engineer saw Marion walking with his back to the train from a distance of about three-quarters of a mile. They sounded the train's horn when they were approximately 18 seconds away from Marion, but he did not respond. The emergency brake was applied only one second before the train struck Marion. Marion's guardian brought a negligence action against the railroad company and its employees. The defendants argued that the collision was not caused by their negligence but by Marion's failure to exercise ordinary care for his own safety.The trial court granted the defendants' motion for summary disposition, noting that they had attempted to alert Marion of the train's approach and that Marion was old enough to understand the dangers of trains. The plaintiff appealed this decision. The Court of Appeals reversed the trial court's decision, holding that a train engineer has a duty to stop or slow down when a person in the train’s path fails to respond to a warning signal. The defendants then sought leave to appeal to the Supreme Court.The Supreme Court of Michigan affirmed the decision of the Court of Appeals. The court held that when a train operator sees a person on the tracks, there is a presumption that the person will move to a place of safety. However, when it becomes apparent that the person will not or cannot get out of the way, that presumption is overcome, and the train operator has a duty to take steps to avoid a collision. The court found that there were genuine issues of material fact as to whether the defendants were negligent, and therefore, summary disposition was not warranted. The case was remanded to the trial court for further proceedings. View "Marion V Grand Trunk Western Railroad Company" on Justia Law

The case revolves around a dispute between Diamond Transportation Logistics (Diamond) and The Kroger Company (Kroger). In 2010, the two companies entered into a transportation agreement, which was renewed in 2016, for Diamond to transport Kroger's goods. The agreement included an indemnity provision, which allowed Kroger to withhold payments from Diamond for claims against Diamond under certain conditions. In December 2015, a subcontractor of Diamond was involved in a fatal accident while transporting Kroger's goods. The family of the deceased sued both Diamond and Kroger for wrongful death, alleging negligence in Kroger's selection, hiring, and retention of Diamond as a shipper. Kroger demanded Diamond to cover its legal expenses based on the indemnity provision in their agreement. However, Diamond failed to reimburse Kroger, leading Kroger to withhold nearly $1.8 million in shipping payments from Diamond.The case was first heard in the United States District Court for the Southern District of Ohio, where Kroger filed a counterclaim for breach of the transportation agreement's indemnity provision. The district court ruled in favor of Kroger, awarding it $612,429.45 plus interest. Diamond appealed this decision to the United States Court of Appeals for the Sixth Circuit.The Sixth Circuit Court of Appeals affirmed the district court's decision. The main issue was whether the indemnity provision's exception for "liability...caused by the sole negligence or willful misconduct of Kroger" relieved Diamond of its obligation. The court held that the exception did not apply in this case because Kroger's liability for the family's negligent selection, hiring, and retention claim was not caused by its "sole negligence." The court reasoned that Diamond's negligence also played a part in Kroger's liability, and therefore, Diamond was required to cover Kroger's costs in settling the family's claim. View "Diamond Transp. Logistics, Inc. v. Kroger Co." on Justia Law

A pilot, who was injured in an airplane crash in 1985, sought medical benefits for a 2016 spinal surgery and subsequent treatment, as well as for diabetes treatment related to his spinal treatment. The Alaska Workers’ Compensation Board denied his claim, concluding that the 1985 injury was not a substantial factor in the pilot’s spinal problems. The Board also excluded the testimony of the pilot’s biomechanics expert due to non-compliance with Board regulations. The Alaska Workers’ Compensation Appeals Commission affirmed the Board’s decision, finding substantial evidence in the record to support the Board’s decision and that the Board had not abused its discretion in its procedural rulings.The Supreme Court of the State of Alaska affirmed the Commission’s decision. The court found that substantial evidence supported the Board's decision that the 1985 injury was not a substantial factor in the pilot's spinal problems. The court also found that the Board did not abuse its discretion by excluding the testimony of the pilot's biomechanics expert due to non-compliance with Board regulations. The court further held that the Board did not have an obligation to secure the testimony of a particular witness, and that the pilot's failure to secure a witness's testimony did not create an obligation for the Board to do so. View "Jespersen v. Tri-City Air and Alaska Insurance Guaranty Company" on Justia Law

The plaintiffs, Jennifer Zeno-Ethridge and Dennis Ethridge, appealed from the trial court's grant of summary judgment in favor of the defendants, Comcast Corporation, Eustis Cable, and Green Mountain Flagging. The suit arose from an incident in which Jennifer witnessed a fatal accident involving a utility truck and a flagger while she was driving. Following the incident, she was diagnosed with post-traumatic stress disorder (PTSD) and depression.Jennifer sued the defendants for negligent infliction of emotional distress (NIED) and negligence, while Dennis filed a loss-of-consortium claim. The trial court granted summary judgment to the defendants, determining that Jennifer's contact with the flagger’s blood and brain matter did not constitute a "physical impact from external force" necessary for a NIED claim. It also concluded that Jennifer's PTSD diagnosis did not satisfy the "actual injury" requirement for a negligence claim.On appeal, the Vermont Supreme Court affirmed the lower court's decision, holding that the act of Jennifer stepping in the flagger's blood and brain matter was not a physical impact from an external force. Furthermore, the court clarified that a PTSD diagnosis alone is insufficient to satisfy the “actual injury” requirement of a negligence claim, as it is a mental or emotional harm, rather than a physical one. Consequently, Jennifer's NIED and negligence claims failed as a matter of law. Therefore, the defendants were entitled to summary judgment on Dennis's loss-of-consortium claim, which was dependent upon the success of Jennifer's claims. View "Zeno-Ethridge v. Comcast Corporation" on Justia Law