Sheehan v. St Paul & Duluth Railway Case Brief

Summary of Sheehan v. St Paul & Duluth Railway, U.S. Circuit Court of Appeals, Seventh Circuit, 1896

Facts: P Sheehan was walking of D’s railway track when his foot became stuck between 2 portions of the track. Unable to dislodge the foot before the approaching train could stop, D’s foot was run over. He now brings an action of negligence in light of personal injury.

Procedure: TC enters directed verdict for D. Circuit CT affirms.

Issue of Law: Is the train company obligated to exercise diligence to ensure the safety of trespassers in remote areas where they are extremely unlikely to come into contact with a reasonably prudent person? No.

Rule of Law: The railway is not bound in service to trespassers. Those who enter on to tracks assume their own risks, particularly in such remote areas of track.

Court’s Rationale: The railway company owes a public duty to areas such as street crossings where it is presumable that persons would come in contact with a train. In this case, no such duty is owed. The P was actually trespassing on the land of the railway in a remote location where the probability of a person coming into contact with a train was highly unlikely, in the absence of the P’s trespassory actions.

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