Jaranowski v. Indiana Harbor Belt Railroad Co., No. 22-2437 (7th Cir. 2023)
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Jaranowski worked as a conductor for the Railroad for 22 years. While operating a railroad switch in 2020, he seriously injured his neck. He sued the railroad under the Federal Employers’ Liability Act (FELA), 45 U.S.C. 51, alleging that he was injured because the railroad failed to maintain the switch properly. He accused the railroad of ordinary negligence and negligence per se based on alleged violations of Federal Railroad Administration (FRA) Track Safety Standards, 49 C.F.R. 213. The district court concluded that Jaranowski had failed to present evidence that would support a finding that the railroad had actual or constructive notice of any defect in the switch before he was injured and granted the Railroad summary judgment.
The Seventh Circuit reversed. Actual or constructive notice is required to violate the federal Track Safety Standards, however, Jaranowski presented sufficient evidence to create a genuine dispute as to whether the railroad at least should have known that the switch was defective before he was injured. A reasonable jury could accept Jaranowski’s account of the facts and the report of his expert, who examined the switch, to conclude that the Railroad’s prior inspection was performed without due care.
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