Justia Transportation Law Opinion Summaries

A woman was struck and injured by a bus in Bangor, Maine. The bus was operated as part of a public transit system known as the Community Connector, which serves several municipalities and the University of Maine. The City of Bangor oversees daily operations of the Community Connector, but the precise extent of involvement by the neighboring towns and cities is disputed. It is also unclear whether the bus that struck the plaintiff was running on a Community Connector route or a Bangor-only route; the buses for both services look the same.The plaintiff filed a complaint in the Penobscot County Superior Court against the City of Bangor, the Community Connector, and several neighboring towns and cities, alleging negligence and asserting that the Community Connector operated as a joint venture among the defendants. The municipalities moved for summary judgment, arguing they were immune from suit under the Maine Tort Claims Act. The Superior Court denied summary judgment, holding that the municipalities had not established that there were no material disputes of fact regarding their involvement or possible joint venture status. The court also denied a motion for reconsideration.On appeal, the Maine Supreme Judicial Court considered whether the municipalities were entitled to immunity as a matter of law. The Court found that key factual questions remained unresolved, including whether the municipalities exercised direct control over the bus or its driver and the nature of their participation in the Community Connector. Because these factual disputes must be resolved by the trial court before determining the applicability of immunity, the Maine Supreme Judicial Court dismissed the appeal as interlocutory, leaving the issue of immunity to be addressed after further factual development in the trial court. View "Fisher v. Town of Hampden" on Justia Law

A man traveling with his family, including his thirteen-year-old daughter, on Delta Air Lines was reported by a flight attendant for suspected human trafficking or sexual abuse after comforting his distressed daughter during turbulence. The flight attendant relayed her suspicions to the flight captain, who then involved the airport station manager, resulting in a call to law enforcement. Upon landing, police detained and questioned the man and his daughter but found no probable cause for arrest. The incident caused the man significant emotional distress and exacerbated his pre-existing PTSD.He subsequently filed a lawsuit in the Circuit Court of the City of Newport News against the flight attendant, Delta, and Endeavor Air, alleging negligence, intentional infliction of emotional distress, tortious interference with parental rights, and false imprisonment. The defendants removed the case to the United States District Court for the Eastern District of Virginia and moved to dismiss, claiming immunity under Virginia Code § 63.2-1512. The district court agreed, holding that the defendants were immune because the report, even if made only to law enforcement and not to social services, was made in good faith and without malicious intent. The man appealed, and the United States Court of Appeals for the Fourth Circuit was uncertain whether the immunity statute applied in this context and certified the legal question to the Supreme Court of Virginia.The Supreme Court of Virginia, upon review of the certified question, held that Virginia Code § 63.2-1512 does not provide immunity to a nonmandatory reporter who, in good faith, reports suspected child abuse to law enforcement without also contacting a Department of Social Services employee or the designated hotline. The Court reasoned that the statutory language is clear and limits immunity to specific categories, which do not include complaints made solely to law enforcement by nonmandatory reporters. The answer to the certified question was “no.” View "Cupp v. Delta Air Lines, Inc." on Justia Law

The case concerns injuries suffered by two individuals, one in New York and one in Pennsylvania, each struck by buses operated by New Jersey Transit Corporation (NJ Transit), a public transportation entity created by the New Jersey Legislature. NJ Transit operates as a “body corporate and politic” with significant powers such as suing and being sued, entering contracts, and raising funds. Its founding statute specifies that debts or liabilities of NJ Transit are not debts of the State of New Jersey, and all expenses must be paid from NJ Transit’s own funds. The State retains substantial control over NJ Transit through board appointments and removal powers, veto authority, and some legislative oversight, but the statute also stresses NJ Transit’s operational independence.After the incidents, the injured parties filed negligence lawsuits against NJ Transit in their home state courts. NJ Transit moved to dismiss both suits, arguing it was an arm of New Jersey and thus entitled to sovereign immunity. The Court of Appeals of New York concluded that NJ Transit is not an arm of New Jersey, allowing the New York suit to proceed. Conversely, the Supreme Court of Pennsylvania found that NJ Transit is an arm of New Jersey and dismissed the Pennsylvania suit.The Supreme Court of the United States reviewed both cases to resolve the conflict. It held that NJ Transit is not an arm of the State of New Jersey and therefore does not share in New Jersey’s interstate sovereign immunity. The Court emphasized that NJ Transit’s status as a legally separate corporation, responsible for its own debts and judgments, and the absence of formal state liability for its obligations, are decisive. The Court affirmed the New York decision, reversed the Pennsylvania decision, and remanded both cases for further proceedings. View "Galette v. New Jersey Transit Corp." on Justia Law

Two former residents of Libby, Montana developed mesothelioma after being exposed to asbestos. The exposure was linked to asbestos-containing vermiculite transported by BNSF Railway Company from a nearby mine. Between 1922 and 1990, BNSF was required by federal law to ship this vermiculite to and from its Libby railyard. Evidence showed that asbestos dust escaped from sealed railcars during transit and switching operations, eventually accumulating in and around the railyard. Both plaintiffs resided or spent considerable time near the railyard during the relevant period.This litigation began when the personal representatives of the decedents’ estates brought negligence and strict liability claims against BNSF in the United States District Court for the District of Montana. BNSF moved for summary judgment on the strict liability claims, arguing that it was protected by the common carrier exception, but the district court denied the motion. After a jury trial, the jury found for BNSF on negligence but for the plaintiffs on strict liability, awarding compensatory damages. The district court subsequently denied BNSF’s renewed motion for judgment as a matter of law on the strict liability claims, prompting BNSF’s appeal.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s interpretation of Montana law de novo. The Ninth Circuit held that the district court erred by applying the common carrier exception too narrowly. The appellate court concluded that BNSF’s transportation of asbestos-containing vermiculite, including the resulting accumulation of asbestos dust, was conducted pursuant to its federally mandated duty as a common carrier. Montana law, including recent precedent from the Montana Supreme Court, supported applying the common carrier exception to shield BNSF from strict liability in these circumstances. The Ninth Circuit reversed the district court’s judgment and remanded with instructions to enter judgment for BNSF. View "Wells v. BNSF Railway Co." on Justia Law

A plaintiff was injured in a collision at an intersection controlled by a malfunctioning traffic signal. Both drivers claimed to have stopped at the flashing red light and to have the right of way. The defendant was driving a truck for his employer, who was also named in the suit under the doctrine of respondeat superior. The plaintiff alleged negligence by the truck driver in failing to maintain control, keep a proper lookout, and yield, and sought damages for injuries and loss of consortium. The employer denied negligence and asserted contributory negligence by the plaintiff.The Circuit Court of the Second Judicial Circuit, Lincoln County, South Dakota, granted the employer’s motion to exclude two of the plaintiff’s expert witnesses, finding their testimony would not aid the jury. The court also denied the plaintiff’s motion to amend the complaint shortly before trial, which sought to add direct negligence claims against the employer and violations of Federal Motor Carrier Safety Regulations (FMCSRs). Additionally, the court refused a jury instruction on those regulations. At trial, the jury found the defendant negligent but determined the plaintiff was contributorily negligent to a degree greater than slight, awarding no damages.The Supreme Court of the State of South Dakota reviewed the appeal. It held that the circuit court did not abuse its discretion in denying the motion to amend as to direct negligence claims against the employer due to untimeliness and prejudice, but erred in denying amendment as to the truck driver’s alleged FMCSR violations, since those allegations provided statutory grounds for existing negligence claims and were not prejudicial or futile. The Supreme Court also held that excluding the expert testimony was an abuse of discretion, as it would have assisted the jury, and that refusal to instruct the jury on FMCSRs was erroneous. The judgment was affirmed in part and reversed in part. View "Hamer V. Duffy" on Justia Law

A passenger was seriously injured after the driver of a remotely rented vehicle, accessed via a membership-based car-sharing service, crashed while under the influence of alcohol. The driver, a university student and approved member of the rental service, reserved the vehicle through a mobile app late at night after consuming alcohol at a party. The process for renting and accessing the car involved no face-to-face interaction with company staff, and the company had no prior knowledge of the driver’s intoxication or any history of impaired driving. Following the crash, the driver was convicted of felony DUI causing injury.The injured passenger sued the car-sharing company and its affiliated vehicle owner in the Superior Court of Yolo County, alleging negligent entrustment for providing the car to an unfit driver, negligent maintenance for failing to include technology to detect driver impairment, and vicarious liability based on vehicle ownership. Both sides moved for summary judgment. The trial court ruled for the defendants, holding that the company owed no duty to inquire about a renter’s impairment at the time of a remote rental, had no duty to install alcohol-detection devices, and was shielded from vicarious liability by federal law (the Graves Amendment).On appeal, the California Court of Appeal, Third Appellate District, affirmed the trial court’s judgment. The court held that remote rental car companies are exempt from statutory requirements to inspect for signs of impairment at the time of rental, per Civil Code section 1939.37, and that courts should not impose additional investigatory duties absent legislative action. The court also held that the Graves Amendment preempts state law claims of vicarious liability based solely on vehicle ownership. Judgment for the defendants was therefore affirmed. View "Tavares v. Zipcar, Inc." on Justia Law

On a rainy night in March 2020, the plaintiff was catastrophically injured while sleeping in a truck driven by his co-worker, both of whom were transporting plasticware from New Jersey to California. The truck, owned and operated by Alliance, a federally licensed motor carrier, crashed on a highway near Oklahoma City. The transportation had been arranged by XPO Logistics, LLC, a federally licensed property broker, which was hired by Sabert Corporation to facilitate shipping but did not own trucks or employ drivers. XPO contracted with Alliance to perform the transport, and Alliance assigned the plaintiff and his co-worker to drive the shipment.After the accident, the plaintiff sued XPO in the Superior Court of Los Angeles County, alleging negligence based on claims that XPO exercised control over the transport and owed a nondelegable duty to maintain a safe workplace. XPO moved for summary judgment, arguing it was solely a broker and not responsible for the carrier’s employee safety. The trial court granted summary judgment for XPO, finding the evidence undisputed that XPO acted as a broker, not a carrier, and did not control Alliance’s transport operations. The trial court also excluded plaintiff’s expert declaration, which had applied the wrong legal standard.The California Court of Appeal, Second Appellate District, reviewed the judgment. The court held that under California law, a broker who hires an independent contractor carrier generally owes no duty of care to the carrier’s employees for workplace injuries, unless the broker has a nondelegable duty or retains and exercises control over the work. The court found no triable issues of fact supporting either exception, and further clarified that the federal Essex Insurance Company v. Barrett Moving & Storage, Inc. test for broker liability for cargo damage is irrelevant to personal injury claims under California law. The judgment for XPO was affirmed. View "Hu v. XPO Logistics, LLC" on Justia Law

The dispute arose from a tragic incident on January 14, 2022, when Marquise Webb and Richie Aaron, Jr. boarded an Amtrak train in Illinois. Although unrelated, both transferred to Amtrak’s River Runner train in Missouri, where Webb fatally shot Aaron without apparent motive during a scheduled stop. Amtrak prohibits firearms onboard, but does not routinely conduct passenger security screenings. After the shooting, Amtrak crew initially dismissed reports of gunfire as fireworks, and medical aid was rendered to Aaron at the next station, but he was pronounced dead shortly thereafter.Following these events, Breayonna Aaron, representing herself, her deceased husband, and their children, filed suit in the United States District Court for the Western District of Missouri against Amtrak for negligence, negligent hiring/training/supervision, and wrongful death, seeking substantial compensatory and punitive damages. Amtrak moved for judgment as a matter of law, but the court submitted the case to a jury, which found Amtrak liable and awarded both compensatory and punitive damages. After trial, Amtrak renewed its motion for judgment as a matter of law or, alternatively, sought a new trial or reduction in punitive damages. The district court denied Amtrak’s motions, but reduced the punitive damages award as constitutionally excessive.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of Amtrak’s motion for judgment as a matter of law de novo. It held that the plaintiffs failed to provide legally sufficient evidence of a duty or causation under any negligence theory presented, as Missouri law requires foreseeability of criminal acts for a duty to exist, and but-for causation for wrongful death. The appellate court reversed the district court’s denial of Amtrak’s motion for judgment as a matter of law and directed the entry of judgment for Amtrak, finding no basis for liability on the claims asserted. View "Aaron v. National Railroad Passenger Corporation" on Justia Law

Ronald B. Panting, an independent contractor serving as a Designated Pilot Examiner (DPE) for the FAA, was conducting a pilot certification checkride for Michael Trubilla in a plane rented from the LeMay Aero Club, a government-affiliated organization. Both men died when the plane crashed during the checkride. Five days prior to the accident, Ronald signed a covenant not to sue the government for injuries sustained while participating in Aero Club activities, applicable to himself and his estate. His spouse, Lynne D. Panting, sued the United States under the Federal Tort Claims Act, alleging negligent maintenance of the aircraft.The United States District Court for the District of Nebraska denied the government’s motion for summary judgment, ruling the covenant not to sue was void as against public policy under Nebraska law. The court did not address Lynne’s alternative argument that the covenant did not apply to Ronald’s activities as a DPE on the day of the crash. Following a bench trial, the district court found the government negligent and entered judgment for Lynne, awarding damages. The government appealed, challenging the district court’s decision regarding the covenant’s validity.The United States Court of Appeals for the Eighth Circuit held that it had jurisdiction to review the denial of summary judgment because the enforceability of the covenant was a purely legal issue. Applying Nebraska law, the appellate court determined the covenant was neither clearly repugnant to public policy nor the product of disparate bargaining power, and that the Aero Club did not provide a public or essential service. The Eighth Circuit reversed the district court’s judgment and remanded for consideration of whether the covenant covered Ronald’s activities as a DPE, and for further proceedings as appropriate. View "Panting v. United States" on Justia Law

Pedro Castaneda died in a traffic accident at an intersection on State Highway 249 that was under construction. At the time, the intersection’s traffic lights were installed but not yet operational, and there was a dispute about whether they were properly covered to indicate their status. Castaneda’s family sued the contractors involved in the project, SpawGlass Civil Construction, Inc. and Third Coast Services, LLC, alleging that negligence in the construction and installation of the traffic signals contributed to the fatal accident. The construction project was governed by an agreement between the Texas Department of Transportation (TxDOT) and Montgomery County, with the County responsible for the project’s design and construction, but with TxDOT retaining authority over the adjacent frontage roads and final approval of plans.The trial court denied the contractors’ motions for summary judgment that sought dismissal under Texas Civil Practice and Remedies Code Section 97.002, which grants immunity to contractors under certain conditions. The contractors appealed. The Fourteenth Court of Appeals affirmed, concluding that Section 97.002 applies only to contractors who are in direct contractual privity with TxDOT, and since neither contractor had a direct contract with TxDOT, they could not invoke the statute’s protection.The Supreme Court of Texas reversed the court of appeals. It held that Section 97.002 does not require direct contractual privity with TxDOT for a contractor to qualify for statutory immunity. The court determined that, based on the summary judgment record, SpawGlass and Third Coast performed work "for" TxDOT within the meaning of the statute, as their activities directly related to frontage roads that TxDOT would own and maintain. The court remanded the case to the court of appeals to determine whether the contractors met the remaining requirements of Section 97.002. View "THIRD COAST SERVICES, LLC v. CASTANEDA" on Justia Law