Baltimore & Ohio Railroad Co. v. Goodman

Facts

Nathan Goodman was driving an automobile truck east toward a railroad grade crossing (a place where a road crosses the tracks at street level). A train running southwesterly across the road at a rate of not less than sixty miles an hour struck and killed him. The line was straight. His widow sued as administratrix of his estate. She argued that Goodman had no practical view beyond a section house two hundred and forty-three feet north of the crossing until he was about twenty feet from the first rail, or twelve feet from danger, and that even then the section house still hid the engine. Goodman had been driving ten or twelve miles an hour and had slowed to five or six miles an hour at about forty feet from the crossing. The opinion says it was thought that there was an emergency in which, so far as appears, Goodman did all he could. The Court did not go into further details of his precise situation, but mentioned that it was daylight and that he was familiar with the crossing. The railroad's defence was that Goodman's own negligence caused his death.

Issues

1. Did the evidence show anything that relieved Goodman, who was killed at a railroad crossing, of responsibility for his own death, so that the railroad's request for a directed verdict should have been granted?
2. When a driver cannot be sure whether a train is dangerously near, what must he do before crossing the tracks, and who decides that standard of conduct, the court or the jury?

Holding

On this evidence nothing relieved Goodman of responsibility for his own death. He was familiar with the crossing and it was daylight, yet he did not stop, or reduce his speed earlier. The Court set the judgment for the widow aside.