Facts
- John Pokora drove a truck in Springfield, Illinois, toward a railroad crossing at Tenth and Edwards Streets to reach an ice depot.
- The crossing involved four tracks: an eastern switch track, the main line, and two western switch tracks.
- A string of boxcars on the switch track near the crossing obstructed Pokora’s view northward along the tracks.
- Pokora stopped, looked north from a point near the switch, and listened; he heard no bell or whistle.
- As he proceeded across, a passenger train approached from the north on the main line and struck his truck at about 25–30 mph.
- Evidence permitted a finding that, because of the obstruction and limited distance between the switch and main track (and train/boxcar overhang), the train may not have been visible from Pokora’s seat in time to stop safely.
Issues
- Whether Pokora was contributorily negligent as a matter of law for crossing with an obstructed view without getting out of his truck to look for an oncoming train.
- Whether the trial court properly directed a verdict for the railroad, or whether contributory negligence had to be submitted to the jury.
Decision
- The Supreme Court reversed the judgment for the railroad and held that contributory negligence was a jury question on this record.
- The Court rejected a categorical rule that a driver with an obstructed view must exit the vehicle and inspect the tracks before crossing.
- Applying the directed-verdict standard, the Court held that the evidence, viewed favorably to Pokora, did not compel a finding of contributory negligence.
- The case was remanded for proceedings consistent with submitting the negligence question to the jury.
Legal Principles
- The defendant bears the burden of proving contributory negligence as a defense in a personal-injury action.
- On a motion for directed verdict at the close of the plaintiff’s evidence, courts must view evidence and reasonable inferences in the light most favorable to the plaintiff.
- A court may declare a fixed standard of care as a rule of law only when noncompliance is so plainly negligent that reasonable minds could not disagree.
- There is no general legal duty requiring a motorist to get out of a vehicle to look for trains at an obstructed crossing; the reasonableness of precautions depends on the specific circumstances and is ordinarily for the jury.
Conclusion
Because the obstructed crossing, the absence of audible warnings, and the physical constraints could support a finding that Pokora acted reasonably, the Supreme Court held that contributory negligence was not established as a matter of law and had to be decided by a jury rather than by directed verdict.