Harris v. Norfolk Southern Railway Co., No. 13-1975 (4th Cir. 2015)Annotate this Case
Plaintiff was injured as the result of a train derailment. Plaintiff filed this negligence action in state court against Norfolk Southern Railway Company seeking both compensatory and punitive damages. Before trial, the district court granted summary judgment for Plaintiff on the issue of whether Norfolk Southern’s negligence cause the derailment and granted summary judgment against Plaintiff on his claim for punitive damages. After a jury trial on the issue of Plaintiff’s compensatory damages, the jury awarded Plaintiff $2,977,383. The Fourth Circuit reversed, holding that the district court (1) erred in granting partial summary judgment to Plaintiff on the issue of Norfolk Southern’s liability for the accident because, while Plaintiff established that Norfolk Southern breached its duty as a matter of law to properly inspect the track, a genuine issue of material fact exists as to whether Norfolk Southern’s breach proximately caused the derailment and Plaintiff’s injuries; and (2) properly granted summary judgment on Plaintiff’s punitive damages claim.