Walter G. Herndon v. National Railroad Passenger Corporation

Summary

The District of Columbia Court of Appeals affirmed summary judgment for Amtrak in a Federal Employers’ Liability Act negligence action brought by an injured conductor. The court held that federal railroad speed regulations controlled claims based on endemic, long-term track conditions and that the plaintiff had not shown a particularized immediate hazard falling within the relevant exception.

Holdings

1. When a train operates within the speed limit established under the Federal Railroad Safety Act, the federal speed limit is determinative and bars a FELA excessive-speed claim based on hazards or conditions endemic and long-term to the track.
2. The Easterwood exception is limited to a specific, individual, immediate hazard requiring the train to slow or stop; general knowledge of a chronically dangerous or rough track condition does not qualify.
3. Summary judgment for Amtrak was proper because, even viewing the evidence in Herndon's favor, he presented no facts showing that a specific immediate track defect caused the injury or required Amtrak to reduce speed.

Questions Presented

1. Whether FRSA speed regulations barred Herndon's FELA claim that the train was traveling at an excessive speed because of endemic, long-term track conditions.
2. Whether Herndon presented evidence bringing his claim within the Easterwood exception for a specific, individual hazard requiring the train to slow or stop.
3. Whether the trial court properly granted summary judgment to Amtrak.

Disposition

affirmed