P was driving a truck and came to a railroad crossing. D's boxcars were on one of the tracks, blocking P's view of the rest of the track.
P stopped, looked, and listened as well as he could and proceeded slowly. P was hit by a train.
P sued D in negligence.
Procedural History:
Trial court directed verdict for D.
Circuit COA affirmed.
SCOTUS reversed and remanded.
Issues:
What is the standard of care for approaching railroad crossings?
Holding/Rule:
A person is required to slow down and look when he approaches a railroad crossing. A person is not required to stop and get out of the vehicle, especially if it is dangerous to do so.
Additionally, courts should be careful about creating "rules of law" since they hardly ever cover every possible scenario.
Reasoning:
It can be inferred that the truck was already in a zone of danger when it stopped; thus, it would have been dangerous for P to get out and look.
P's case should get to the jury unless, as a matter of law, he was subject to a duty to get out of the vehicle before it crossed the switch and survey the scene.
Judges should be cautious in framing standards of behavior that amount to rules of law. There are always extraordinary circumstances that can arise and render the rule useless.
