Roback et al. v. Washington County Railroad Co. et al.

Summary

The Vermont Superior Court, Windsor Unit, grants separate motions for summary judgment filed by Washington County Railroad Company and the State of Vermont. The court holds that plaintiffs failed to provide sufficient evidence of breach, damages, or bad faith concerning a deeded railroad-crossing easement and concludes that the crossing’s closure was based on safety considerations rather than inadequate maintenance. The court also addresses claims for breach of contract, breach of the implied covenant of good faith and fair dealing, and tortious interference with contractual relations.

Holdings

1. The State was entitled to summary judgment because Plaintiffs failed to produce evidence from which a reasonable factfinder could conclude that inadequate maintenance by the State caused or allowed the unsafe conditions warranting closure, and they also failed to produce evidence establishing recoverable damages.
2. The State was entitled to summary judgment because the implied-covenant claim was either duplicative of the breach-of-contract claim or unsupported by evidence of improper motive, bad faith, injury, or causation.
3. Plaintiffs could not maintain an independent freestanding claim for bad faith because the claim was duplicative of the implied-covenant claim and Plaintiffs identified no legal authority supporting an extra-contractual bad-faith cause of action.
4. The Railroad was entitled to summary judgment because Plaintiffs failed to produce evidence of actual harm or improper interference.

Questions Presented

1. Whether the State was entitled to summary judgment on the breach-of-contract claim arising from the 1911 deeded easement.
2. Whether the State was entitled to summary judgment on the claim for breach of the implied covenant of good faith and fair dealing.
3. Whether Vermont recognizes an independent freestanding claim for bad faith separate from a contractual claim or implied-covenant claim.
4. Whether the Railroad was entitled to summary judgment on the claim for tortious interference with contractual relations.

Disposition

other