## Facts

- Daniels drove an automobile toward a railroad crossing in Savannah, Georgia, controlled by crossing bars operated from a signal tower.
- The bars were raised as he approached, and Daniels entered the crossing.
- The towerman lowered the bars while Daniels was on the tracks, trapping the automobile between the bars as a train approached.
- Daniels stalled, exited, and pushed the automobile off the train’s path; the train passed without striking him or the vehicle.
- After the bars were raised, Daniels attempted to restart the car while still frightened and nervously excited from the emergency.
- Forgetting the car remained in top gear and failing to properly adjust engine controls, Daniels cranked the engine; it “kicked back,” throwing him into the radiator and causing facial injuries and broken teeth.
- Daniels alleged the negligent lowering of the bars caused the emergency and ensuing fright, which in turn caused the mistake that produced his physical injury.

## Issues

1. Whether the railroad’s alleged negligent operation of the crossing bars could be the proximate cause of injuries occurring after the train passed, during Daniels’s attempt to restart his automobile.
2. Whether Daniels’s fright-induced conduct was a foreseeable reaction operating as a “medium” of the railroad’s negligence, or a new, independent cause severing liability.
3. Whether proximate cause was resolvable on demurrer or required jury determination on the pleaded facts.

## Decision

- The Court of Appeals of Georgia affirmed the denial of the railroad’s demurrer.
- The petition sufficiently alleged a causal chain allowing a jury to find the railroad’s negligence a proximate cause of Daniels’s injuries.
- Proximate cause, on these allegations, was a question for the jury rather than a matter of law on the pleadings.

## Legal Principles

- Legal causation is narrower than factual causation; the law treats ordinary, prudent conduct in the setting as a condition, and treats a negligent act as the juridical cause when, under ordinary human probabilities, the injury would not have occurred without that negligent disturbance.
- A negligent act may be deemed the sole and proximate cause when it acts upon an otherwise normal situation and produces an injury that probably would not have occurred absent the negligence, without another wrongful act intervening in the near sequence.
- When a person, placed in fright by another’s negligence, acts and is injured, whether the frightened person’s act is merely the instrument through which the negligence operated or an independent legal cause turns on:
  - whether the negligent situation was such as would naturally tend to produce that degree of fright; and
  - whether a normally prudent person, so frightened, would be likely to act in a similar way.
- If the frightened reaction is a foreseeable product of the risk created by the negligence, it may not break proximate causation; the issue is ordinarily for the factfinder.

## Conclusion

The court allowed the case to proceed because the pleaded facts permitted a jury to find that negligently trapping Daniels on the tracks foreseeably caused fright and a reasonable, stress-related mistake leading to injury, making proximate cause inappropriate for dismissal on demurrer.


Atlantic Coast Line R.R. Co. v. Daniels, 8 Ga. App. 775, 70 S.E. 203 (Ct. App. 1911)