UNION PACIFIC RAILROAD COMPANY v. PRADO (Opinion)
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The case involves a fatal accident that occurred at a private railroad crossing owned by Ezra Alderman Ranches, Inc. and operated by Union Pacific Railroad Company. Rolando Prado, Jr. died when his vehicle was struck by a Union Pacific train at the crossing. His family members (the Prados) sued both Union Pacific and Ezra Alderman Ranches, Inc. for negligence. The central issue before the Supreme Court of Texas was whether the evidence was sufficient to create a fact issue on whether the railroad crossing, which was protected by both a stop sign and a crossbuck sign, was "extra-hazardous" and whether the landowner knew it was "unreasonably dangerous."
The court held that the evidence was insufficient to support a finding that the crossing was extra-hazardous. The court reasoned that the crossing had a stop sign in addition to the usual crossbuck sign, and anyone who actually stopped at the sign could clearly see a train coming from either direction. The expert testimony that suggested drivers would not stop at a particular stop sign because it "lacks credibility" did not establish that all reasonably prudent drivers would not, much less could not, stop at the sign.
The court also held that there was no evidence to support a finding that the landowner, Ezra Alderman Ranches, Inc., had actual knowledge that the crossing was unreasonably dangerous. The court determined that the evidence indicated that the landowner knew of the high volume of traffic at the crossing, but it did not establish that the landowner had actual knowledge that the crossing was unreasonably dangerous.
The court reversed the decision of the court of appeals and reinstated the judgment of the trial court in favor of Union Pacific and Ezra Alderman Ranches, Inc.
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