Justia Transportation Law Opinion Summaries

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The case involves a fatal accident that occurred at a private railroad crossing owned by Ezra Alderman Ranches, Inc. and operated by Union Pacific Railroad Company. Rolando Prado, Jr. died when his vehicle was struck by a Union Pacific train at the crossing. His family members (the Prados) sued both Union Pacific and Ezra Alderman Ranches, Inc. for negligence. The central issue before the Supreme Court of Texas was whether the evidence was sufficient to create a fact issue on whether the railroad crossing, which was protected by both a stop sign and a crossbuck sign, was "extra-hazardous" and whether the landowner knew it was "unreasonably dangerous."The court held that the evidence was insufficient to support a finding that the crossing was extra-hazardous. The court reasoned that the crossing had a stop sign in addition to the usual crossbuck sign, and anyone who actually stopped at the sign could clearly see a train coming from either direction. The expert testimony that suggested drivers would not stop at a particular stop sign because it "lacks credibility" did not establish that all reasonably prudent drivers would not, much less could not, stop at the sign.The court also held that there was no evidence to support a finding that the landowner, Ezra Alderman Ranches, Inc., had actual knowledge that the crossing was unreasonably dangerous. The court determined that the evidence indicated that the landowner knew of the high volume of traffic at the crossing, but it did not establish that the landowner had actual knowledge that the crossing was unreasonably dangerous.The court reversed the decision of the court of appeals and reinstated the judgment of the trial court in favor of Union Pacific and Ezra Alderman Ranches, Inc. View "UNION PACIFIC RAILROAD COMPANY v. PRADO" on Justia Law

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The City of Norwalk sued the City of Cerritos, alleging that Cerritos' ordinance limiting commercial and heavy truck traffic to certain major arteries caused extra truck traffic to be diverted through Norwalk, constituting a public nuisance. The City of Cerritos demurred, arguing that it was immune from liability as the ordinance was enacted under the express authority of the Vehicle Code sections 35701 and 21101. The trial court sustained the demurrer without leave to amend, and Norwalk appealed this decision. The Court of Appeal of the State of California, Second Appellate District, affirmed the trial court's decision. The appellate court held that the public nuisance alleged by Norwalk, namely, the diversion of heavy truck traffic and its adverse effects, necessarily and inescapably flowed from the enactment of the Cerritos ordinance, which was expressly authorized by the Vehicle Code. As such, Cerritos was immune from liability for public nuisance under Civil Code section 3482. In addition, the court found no merit in Norwalk's arguments that the ordinance was unreasonable and that Cerritos failed to obtain the state's permission to regulate certain streets. View "City of Norwalk v. City of Cerritos" on Justia Law

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In December 2019, a taxicab driver, Phillip Palmer, shot a heavily intoxicated passenger, Nicholas Young, following a dispute over cab fare. The incident escalated into a physical altercation at a gas station, where Young shoved Palmer twice, causing him to fear for his life. Palmer, who had begun carrying a gun in his cab after hearing about a driver who had been shot by a passenger, fired two shots at Young, hitting him in the neck. Young survived his injuries. At trial, Palmer admitted to the shooting but claimed self-defense. The trial court denied Palmer's request for a self-defense jury instruction, finding Palmer's statements about his means of escape not credible and determining that a reasonable person would not have believed they were in danger of being killed by Young under the circumstances. Palmer was acquitted of attempted murder but found guilty of felonious assault and a firearm specification.The Supreme Court of Ohio reversed the decision of the Twelfth District Court of Appeals, which had affirmed the trial court's judgment. The Supreme Court determined that the trial court had improperly weighed the evidence when performing a sufficiency analysis. The court found that Palmer had presented legally sufficient evidence for each element of self-defense and was therefore entitled to a self-defense jury instruction. The evidence presented, if believed, could convince a trier of fact that Palmer was acting in self-defense. Therefore, the case was remanded for a new trial on the felonious-assault charge and accompanying firearm specification. View "State v. Palmer" on Justia Law

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In Texas, the appellant was stopped by an officer for failing to remain in a single lane of traffic. After the officer smelled alcohol on the appellant's breath and observed signs of intoxication, he obtained a warrant for a blood sample, which showed a blood alcohol content of .174. The appellant was subsequently indicted for felony driving while intoxicated. The appellant filed a pre-trial motion to suppress, arguing that the officer did not have reasonable suspicion for the traffic stop. The trial court denied the motion, and the appellant was convicted. The appellant appealed, and the Third Court of Appeals reversed the conviction, holding that the stop was unlawful because the appellant's failure to maintain a single lane was not unsafe.The Court of Criminal Appeals of Texas considered whether a mistake of law should apply when an officer conducts a search or seizure under an ambiguous law. The court held that the officer's reasonable misinterpretation of the law did not undermine the reasonable suspicion required to conduct the traffic stop. The court noted that at the time of the stop, there was no controlling interpretation of the relevant section of the Texas transportation code from the Court of Criminal Appeals and the intermediate courts were split in their interpretations. The court therefore reversed the court of appeals' decision and affirmed the trial court's judgment. View "Daniel v. State" on Justia Law

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The case revolves around a dispute between two cities, Norwalk and Cerritos, both located in California. In 1974, Cerritos enacted an ordinance restricting commercial and heavy truck traffic to certain major arteries within the city. The ordinance was amended in 2019 and 2020, resulting in the removal of one of these arteries. Consequently, Norwalk sued Cerritos, arguing that the ordinance created a public nuisance by diverting extra truck traffic through Norwalk and thus causing various "adverse effects" linked to heavier traffic flow. Cerritos claimed immunity under Civil Code section 3482, which shields a city from public nuisance liability for actions "done or maintained under the express authority of a statute". The Court of Appeal of the State of California Second Appellate District found that the Vehicle Code explicitly authorized cities to regulate the use of their streets by commercial or heavy vehicles. Therefore, the court held that Cerritos was immune from liability for the public nuisance of diverting traffic into Norwalk. The court stated that the immunity conferred by Civil Code section 3482 applied not only to the specific act expressly authorized by the statute, but also to the consequences that necessarily stemmed from that act. The court affirmed the judgment in favor of Cerritos. View "City of Norwalk v. City of Cerritos" on Justia Law

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In this case, a woman was severely injured while moving an inoperable airplane owned by her husband. She sought recovery from her husband's homeowner's insurance policy. The insurance policy, however, excluded injuries "arising out of" the ownership, maintenance, use, loading or unloading of an aircraft. The woman argued that the policy should cover her injury because, in her view, the aircraft had become mere "parts" after her husband removed the wings, elevators, and tail rudder. The lower court disagreed and concluded that her injuries were not covered by the policy. The woman appealed this decision.The Supreme Court of the State of Alaska agreed with the lower court’s interpretation of the homeowner's insurance policy exclusion. The court maintained that regardless of whether the airplane was considered an aircraft or a collection of airplane “parts” when it injured the woman, the injury arose out of the husband’s ownership of the airplane. This interpretation was supported by the clear language of the policy which excluded coverage for bodily injury arising out of ownership or maintenance of an aircraft. As a result, the court affirmed the lower court’s decision. View "Thompson v. United Services Automobile Association" on Justia Law

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In this case, the Supreme Court of Maryland held that the Administrative Law Judge (ALJ) did not err in concluding that law enforcement had reasonable grounds to believe that Rahq Deika Montana Usan was driving a vehicle while impaired by alcohol, drugs, or both. The ALJ found substantial evidence to support this belief, including Usan's erratic driving, red and glassy eyes, slow and sluggish movement, and failure to perform three Standardized Field Sobriety Tests (SFSTs) successfully. The court also affirmed the ALJ's finding that law enforcement, having reasonable suspicion of a driver impaired by alcohol, drugs, or both, may request testing pursuant to the Maryland Transportation Article § 16-205.1. The court further held that Usan violated the statute by refusing to submit to the requested testing. As a result, the Supreme Court of Maryland reversed the decision of the Circuit Court for Charles County, which had overturned the ALJ's decision to suspend Usan's driver's license. View "Motor Vehicle Admin. v. Usan" on Justia Law

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In this case, Patrick Tvrdy was convicted of manslaughter and sentenced to 12 to 16 years' imprisonment following a vehicle-motorcycle collision that resulted in the death of the motorcycle driver, Brady Sweetser. Tvrdy appealed on three grounds: that the district court used erroneous jury instructions relating to motor vehicle homicide instead of manslaughter, that the evidence was insufficient to support his conviction, and that the sentence imposed was excessive.The Nebraska Supreme Court affirmed the district court's decision. The court found that the jury instructions correctly stated the law and were not misleading. The court noted that the law in Nebraska does not consider a victim's negligence as a defense to manslaughter unless that negligence is the sole proximate cause of the death. This principle was correctly reflected in the jury instructions.Regarding the sufficiency of the evidence, the court found that there was enough evidence to support Tvrdy's conviction. The court emphasized that an appellate court does not resolve conflicts in the evidence, pass on the credibility of witnesses, or reweigh the evidence. The court found that there was sufficient evidence of Tvrdy's intoxication and that there was never enough time for Tvrdy to complete his left turn without causing Sweetser, who had the right of way, to collide with him.As to the sentence, the court found no abuse of discretion by the district court. Tvrdy's sentence was within the statutory limits for his offense, and the court noted his criminal history of multiple speeding and possession of marijuana offenses, as well as a driving under the influence offense. View "State v. Tvrdy" on Justia Law

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A group of petitioners, including several municipalities, private individuals, and organizations, challenged the Federal Aviation Administration's (FAA) approval of a new terminal for the Trenton-Mercer Airport. The petitioners alleged that the FAA’s decision violated the National Environmental Policy Act (NEPA) by failing to fully consider the environmental impact of the new terminal, among other things. The United States Court of Appeals for the Third Circuit found that the FAA had adequately considered the environmental impact of the new terminal and had not violated NEPA. The court found that the FAA reasonably concluded that the new terminal would not induce additional air traffic, and therefore, would not result in increased noise or air pollution. The court also found that the FAA had conducted a reasonable environmental justice analysis and did not need to perform a health risk assessment. The Court of Appeals denied the petitioners' request to review the FAA's decision. View "Trenton Threatened Skies Inc v. FAA" on Justia Law

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Plaintiff-Appellant Joseph Brent Mattingly, an employee of R.J. Corman Railroad Services, LLC (“Corman Services”), suffered injuries while repairing a bridge owned and operated by Memphis Line Railroad (“Memphis Line”). Mattingly filed a lawsuit seeking recovery under the Federal Employers’ Liability Act (“FELA”), which covers employees of common carriers by railroad. The U.S. District Court for the Eastern District of Kentucky granted summary judgment in favor of the defendants, ruling that Mattingly was not employed by a common carrier, a prerequisite for FELA coverage.On appeal, the U.S. Court of Appeals for the Sixth Circuit affirmed the lower court's decision. The appellate court rejected Mattingly’s argument that Corman Services, his employer, was a common carrier because it was part of a “unitary” railroad system managed by Corman Group. The court held that Corman Services' bridge repair and construction services did not provide an inextricable function for Memphis Line’s common carrier services and thus, did not qualify as a common carrier under FELA. The court further rejected Mattingly’s assertion that he was a “subservant” of a common carrier. The court found that Mattingly failed to demonstrate that Memphis Line, a common carrier, controlled or had the right to control the daily operations of Corman Services, as required to establish a master-servant relationship under common law.The court also held that Mattingly's claims regarding discovery issues were unpreserved for appeal, as he did not adequately inform the district court of his need for discovery in compliance with Federal Rule of Civil Procedure 56(d). View "Mattingly v. R.J. Corman R.R. Grp., LLC" on Justia Law