## Facts

- Mr. and Mrs. Reynolds and their party were ticketed passengers waiting at Morrogh Station to board an eastbound Texas & Pacific Railway passenger train that arrived around 2 a.m.
- A freight train on a switch track lay between the depot and the passenger train; railroad employees uncoupled freight cars to create a passage for passengers.
- Passengers descended several steps from the depot to a lower platform and then had to turn sharply right and pass between the uncoupled freight cars to reach the passenger cars.
- The steps had no railing; a ditch lay to the left, and a narrow platform at the bottom ended near a slope that dropped toward a ditch in front.
- Although trains regularly stopped there at night, the railroad provided no stationary lighting for the steps or platform; there was no moon, and the freight cars blocked light from the engine and passenger cars.
- While attempting to reach the train through the dark passage, Mrs. Reynolds fell from the steps or platform and suffered serious injuries.
- The plaintiffs sought damages for Mrs. Reynolds’s injuries and for Mr. Reynolds’s related losses; the trial court entered judgment for plaintiffs, and the railroad appealed.

## Issues

1. Whether a railroad common carrier must provide a reasonably safe, properly lighted passage between its depot and trains for passengers, particularly at night.
2. Whether inadequate lighting and an unsafe passageway were a legal cause of Mrs. Reynolds’s fall when it was possible she might have fallen even absent the railroad’s negligence.
3. Whether Mrs. Reynolds’s alleged contributory negligence barred recovery.

## Decision

- The Louisiana Supreme Court affirmed the judgment for the plaintiffs.
- The court held the railroad owed passengers a duty to furnish safe passage between depot and train and, at stations used at night, proper and sufficient lighting to make the way reasonably safe.
- The court found the railroad breached that duty by requiring passengers to traverse a crooked, hazardous route in darkness.
- The court held causation was established because the negligence materially increased the likelihood of the type of accident that occurred; a mere possibility the fall could have occurred without negligence did not absolve the railroad.
- The court rejected the railroad’s contributory-negligence defense as insufficient on the record to defeat recovery.

## Legal Principles

- A railroad as a common carrier must provide safe modes of passage between its depot and its trains, including safe and convenient approaches used for passenger ingress and egress.
- Where trains stop at night, the carrier must provide proper and sufficient lighting to make the route reasonably safe.
- Once negligence is shown that naturally tends to produce the kind of accident that occurred and substantially increases its likelihood, causation is not defeated by speculation that the accident might have happened even without the negligence.
- Allowing passengers to proceed in darkness over a hazardous approach can constitute gross negligence by a carrier.

## Conclusion

The court affirmed liability because the railroad failed to provide a reasonably safe, adequately lighted approach for boarding at night, and the unsafe, unlighted conditions made Mrs. Reynolds’s injury a natural and probable result even though it was conceivable she could have fallen under safer conditions.


Reynolds v. Tex. & Pac. Ry. Co., 37 La. Ann. 694 (La. 1885)