Soo Line RR. Co. v. Werner Enter., No. 15-1373 (8th Cir. 2016)
Annotate this CaseAfter a truck driven by a Werner employee struck a train operated by Canadian Pacific, causing a tanker car to spill the chemical it was carrying, Canadian Pacific filed suit against Werner for the clean-up costs under theories of trespass, nuisance, and negligence. The court concluded that the district court properly granted summary judgment to Werner on the trespass claim where Canadian Pacific did not argue that the employee entered the intersection intentionally, and its theory that the employee intentionally hid a fatigue diagnosis, even if true, was insufficient to make out a trespass claim. Because negligence was the only potential basis of wrongful conduct that was presented to the jury, its finding that the employee was not negligent is fatal to Canadian Pacific’s nuisance claim. The court further concluded that federal regulations do not foreclose state law defenses to negligence claims. In this case, when viewed in the light most favorable to Werner, the evidence was sufficient to enable a reasonable jury to find that the employee was incapacitated due to an acute cardiac event, and therefore not negligent in operating his truck. Finally, the court concluded that the district court’s instructions adequately submitted the issues to the jury and that it did not abuse its discretion in denying the requested instruction. Accordingly, the court affirmed the judgment.
Court Description: Wollman, Author, with Bye and Gruender, Circuit Judges] Civil case - Negligence. In action to recover cleanup costs the plaintiff railroad incurred as a result of a collision between one of its trains and one of Werner's trucks, the district court did not err in granting Werner summary judgment on plaintiff's trespass and nuisance claims because plaintiff's evidence was insufficient to establish a trespass claim and because, in the absence of negligence by Werner, there could be no nuisance claim under Minnesota law; federal law did not preempt Minnesota's sudden-incapacitation defense; evidence was sufficient for a jury to find that Werner's driver had become suddenly incapacitated as a result of a cardiac event and was not, therefore, negligent in the operation of the truck; challenge to jury instructions rejected.
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