Robinson v. CSX Transportation, Inc.-Florida’s Fifth District Court of Appeals
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James Robinson was injured at work when the CSX Transportation, Inc. train he was conducting struck a tractor-trailer rig at a public railroad crossing. The truck entered the crossing without heeding the activated warning signals indicating Robinson’s oncoming train.
Robinson filed suit against CSX under the Federal Employers’ Liability Act (FELA).
Robinson’s accident report filed with his employer immediately following the accident cited the truck driver as being at fault for the accident.
On the accident report form, Robinson also noted that his employer failed to provide him with specialized safety equipment, including a backup hose or a shoving platform, for the maneuver he was performing at the time of the collision: a shoving movement of 16 cars through a public crossing. Although Robinson and other CSX employees proffered that shoving platforms and backup hoses are regularly used during the type of maneuver Robinson was performing, the trial court excluded the safety equipment evidence on the basis that no witnesses proffered that either tool was routinely used and readily available at the railroad yard on the day of the accident.
The jury was not made aware of Robinson’s notation of unavailable safety equipment on the accident report.
The jury returned a verdict in favor of CSX.
Robinson appealed the verdict, and the Fifth District Court of Appeals reviewed the trial court’s exclusion of evidence for an abuse of discretion.
The appeals court found that the trial court abused its discretion by excluding evidence about the safety equipment. Citing case law, the court pointed out that CSX breached its responsibility to provide a reasonably safe workplace because safer alternatives for Robinson’s duties existed at the time of his accident, even though they were not provided to him.
The appeals court also found that the trial court abused its discretion by allowing the jury to see only a portion of Robinson’s accident report. This gave the jury a distorted view of his account, making it appear as if he placed blame only on the truck driver.
The court reversed the judgment entered in favor of CSX and remanded for a new trial.
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