Oxford Lake Line Co. v. Stedham

Summary

The Alabama Supreme Court considered whether a railroad was liable for injuries caused when a mule was frightened by steam escaping from a locomotive near a sharp curve. The court held that the evidence showed the steam was released in the customary and necessary manner by a careful engineer, with no negligence, recklessness, or wanton conduct. The judgment was reversed and the case remanded.

Holdings

1. The sixth count sufficiently alleged negligence and was not subject to demurrer.
2. A railroad is not liable for injuries resulting from a mule's fright at steam escaping from a train when the release was no more than customary and necessary to control the engine, and was not recklessly or wantonly caused.
3. The trial court erred by refusing the defendant's requested general charge directing the jury to find for the defendant.

Questions Presented

1. Whether the sixth count sufficiently alleged negligence in stating that the mule was frightened by the engine and cars owing to the negligence of the railroad's employees.
2. Whether a railroad is liable for injuries caused by a mule frightened by steam escaping from a train when the steam release was customary, necessary to slow the train for a sharp curve, and not recklessly or wantonly caused.
3. Whether the trial court erred by refusing the defendant's requested general charge directing a verdict for the defendant.

Disposition

reversed_and_remanded