Facts
- A motorist was killed in a collision with a train at a railroad-highway grade crossing.
- The decedent’s survivors brought a wrongful-death negligence action against the railroad.
- The crossing where the collision occurred did not have railroad-highway crossing warning signs (commonly referred to as crossing signs/crossbucks).
- During trial, the plaintiffs introduced evidence of a railroad-industry standard that called for railroads to place railroad-highway crossing signs at all railroad crossings to warn motorists of train traffic.
- Over the railroad’s objection, the trial judge admitted the industry-standard evidence.
- The trial judge instructed the jury that a violation of an industry standard may be considered, along with the other facts and circumstances, as evidence of negligence (and not as conclusive proof of negligence).
- The jury returned a verdict for the plaintiffs, and the railroad appealed.
Issues
- Whether the trial court erred by admitting evidence of a railroad-industry standard requiring railroad-highway crossing signs at all crossings when no such signs were present at the crossing involved in the death.
- Whether the trial court erred by instructing the jury that violation of an industry standard may be considered—together with other facts—as evidence of negligence.
Decision
- The appellate court affirmed the judgment for the plaintiffs.
- It held that the trial court did not commit reversible error by allowing the jury to hear evidence of the railroad-industry standard regarding crossing signage.
- It approved the jury instruction explaining that an industry-standard violation may be considered as evidence of negligence when weighed with the other evidence.
Legal Principles
- Evidence of an industry standard or customary practice may be admitted in a negligence case because it can aid the jury in deciding what reasonable care required under the circumstances.
- A party’s failure to meet an industry standard is not automatically negligence as a matter of law; it is a fact the jury may weigh with all other evidence in deciding whether the defendant acted reasonably.
- A jury instruction is proper when it accurately explains the limited role of industry standards: relevant to the negligence inquiry, but not conclusive.
Conclusion
St. Louis-San Francisco Railway Co. v. White affirmed a wrongful-death judgment where the trial court admitted evidence of an industry standard requiring railroad-highway crossing signs at all crossings and instructed that noncompliance with that standard could be considered, with other facts, as evidence of negligence.