Justia Transportation Law Opinion Summaries
Articles Posted in U.S. Court of Appeals for the Fourth Circuit
Le Doux v. Western Express, Inc.
Andre Le Doux was driving on Interstate 81 in Virginia when he encountered a sudden traffic standstill due to a torrential downpour. As he braked, a vehicle behind him pushed his van into another vehicle, leaving his van exposed in the left lane. Ervin Worthy, driving a Western Express tractor trailer, saw the heavy rain and braked, but could not stop in time and collided with Le Doux’s van, causing severe injuries to Le Doux.Le Doux sued Worthy for negligence and willful and wanton negligence, and Western Express for vicarious liability and negligent hiring. The United States District Court for the Western District of Virginia excluded expert testimony from Le Doux’s meteorologist and accident reconstructionist due to gaps in radar data and inaccurate GPS timestamps. The court also excluded testimony from Le Doux’s trucking expert, finding it unnecessary for the jury to understand the standard of care for a tractor trailer driver in rainy conditions. Additionally, the court dismissed Le Doux’s negligent hiring claim against Western Express, reasoning that since Worthy was acting within the scope of his employment, the claim was redundant.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court’s exclusion of the expert testimonies, agreeing that the gaps in data and potential jury confusion justified the decision. The court also upheld the exclusion of the trucking expert’s testimony, finding that the jury could understand the necessary standard of care without it. Finally, the court affirmed the dismissal of the negligent hiring claim, holding that since the jury found Worthy not negligent, Western Express could not be liable for negligent hiring. The Fourth Circuit concluded that the district court did not abuse its discretion in its rulings. View "Le Doux v. Western Express, Inc." on Justia Law
CSX Transportation, Inc. v. South Carolina Department of Revenue
This case involved the differences between how ad valorem taxes are determined in South Carolina for railroad property and how they are determined for most other commercial and industrial property. CSXT filed suit against the State, alleging that the property taxes imposed for the 2014 tax year will discriminate against CSXT. CSXT sought a judgment declaring that excluding CSXT from the benefit of the caps of the South Carolina Real Property Valuation Reform Act (SCVA), S.C. Code 12-37-3140(B), violates the Railroad Revitalization and Regulatory Reform Act of 1976, 49 U.S.C. 11501(b)(4), which prohibits the imposition of "another tax that discriminates against a rail carrier." CSXT also sought preliminary and permanent injunctions. The district court ultimately rejected CSXT's section 11501(b)(4) challenge. The court explained that Congress designed section 11501(b)(4) to prohibit taxes that discriminate against railroads. In this case, CSXT alleged that if it is not allowed to benefit from the SCVA cap, its 2014 property tax will be just such a tax. The court concluded that there was no basis for precluding CSXT from proving the claim it alleged – discrimination – and requiring CSXT instead to fit its challenge into a provision that does not even address discrimination and that required proof of facts CSXT has not even alleged. Therefore, the court vacated and remanded for further proceedings because the district court granted judgment against CSXT without ever reaching the question of whether the challenged tax was discriminatory. View "CSX Transportation, Inc. v. South Carolina Department of Revenue" on Justia Law
Conrad v. CSX Transp., Inc.
After CSX charged plaintiff, one of its employees, with "serious" violations of the company's safety policy, plaintiff filed suit under the Federal Railroad Safety Act (FRSA), 49 U.S.C. 20109, alleging that he was disciplined in retaliation for his activities as local chairman of the transportation union. The district court granted summary judgment in favor of CSX, concluding that plaintiff had failed to show that any CSX employee involved in the disciplinary process had also known about his union activities. The court held that the “knowledge” relevant for a retaliation claim under the FRSA must be tied to the decision-maker involved in the unfavorable personnel action. The court concluded that, because plaintiff does not present sufficient evidence that the relevant CSX decision-makers knew of his protected activities, his claims fail as a matter of law at the prima facie stage. Accordingly, the court affirmed the judgment. View "Conrad v. CSX Transp., Inc." on Justia Law