Woods v. Union Pacific Railroad Company
Filed April 15, 2008
Publication ordered April 28, 2008, Second District, Div. One
Cite as 2008 SOS 2517

Judgment on Motion for Directed Verdict Affirmed

Union Pacific Railroad Company (Union Pacific) employed Raymond Woods (Woods) as ground man at its Long Beach Intermodal Container Transfer Facility (ICTF).

Ascending and descending railcars was one of Woods’ regular duties. It is a duty for which he received training.

While descending from an outbound intermodal railcar, Woods sustained an injury. He claimed that vertical handholds on a railcar ladder compromised his leverage and balance. Said injury necessitated two operations, first to his left knee and later to his right knee.

Woods remained employed with Union Pacific. Eventually, he was dismissed.

Consequently, Woods filed a negligence action against Union Pacific under the Federal Employers Liability Act (FELA) and the Federal Safety Appliance Act (SAA).

Woods alleged that Union Pacific “provided an unsafe workplace and engaged in unsafe and negligent practices contrary to its obligations under the FELA and/or provided unsafe railcars to its workers contrary to its obligations under the SAA, thereby directly or indirectly causing his injuries.”

On trial, Wood’ expert testimony testified that the vertical handholds do not comply with the Code of Federal Regulations (CFR) as incorporated by the SAA. He claimed Wood’s injuries were caused by his exposure to unsafe working conditions, including the vertical handholds on the ladder.

On the other hand, Union Pacific’s SAA expert testified that the vertical handholds under scrutiny do not violate the CFR. After which, Union Pacific moved for nonsuit contending that Woods failed to provide evidence of a violation of the SAA.

The court denied said motion. It found credence to Wood’s expert testimony.

After Union Pacific presented its case, it filed a motion for a directed verdict. Woods opposed.

The trial court granted the motion for a directed verdict. It concluded that compliance with the SAA was a question of law. Plaintiff had failed to establish negligence and violation of the SAA.

The trial court granted the motion for directed verdict and eventually entered a judgment in its favor. Thus, appeal followed.

The California Court of Appeal affirmed the decision of the trial court by holding that it did not err in sustaining Union Pacific’s motion for directed verdict. SAA did not prohibit the installation of additional safety appliances onto train cars. Providing both horizontal and vertical handholds on the train cars were not violations of said Act. Moreover, compliance with the act was a question of law.