Benjamin v. United States Steel Corp.

396 So. 2d 332, 1981 La. App. LEXIS 3731
CourtLouisiana Court of Appeal
DecidedFebruary 19, 1981
DocketNo. 11421
StatusPublished
Cited by2 cases

This text of 396 So. 2d 332 (Benjamin v. United States Steel Corp.) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Benjamin v. United States Steel Corp., 396 So. 2d 332, 1981 La. App. LEXIS 3731 (La. Ct. App. 1981).

Opinions

GARRISON, Judge.

Two circumstances of potential legal complication originated with this case, growing as it did out of Samuel Benjamin’s leg injuries received while working with steel beams in a railroad car in New Orleans. The first potential complication involved the multiplicity of other initial defendants with arguable causation roles — in connection with the shipment of the steel from Chicago down to New Orleans — prior to that of the New Orleans Public Belt Railroad, the last possessor of the well traveled box car at the time of the plaintiff’s accident. The second potential complication involved the fact that Benjamin was alone — with the consequent problem of an absence of eyewitnesses — at the time of the incident.

[334]*334The trial judge resolved these issues by granting judgment in favor of the plaintiff and against the New Orleans Public Belt Railroad. The financial breakdown of Benjamin’s judgment was: %9,000.00 for his pain and suffering and $2,707.68 for his loss of wages, making a total of $11,707.68. Legal interest from date of judicial demand, until paid, and all costs were granted to the plaintiff. Following submission to a five man panel of this court, we affirm the trial court’s resolution of the issues.

Initially plaintiff had sued other defendants as well. Elgin-Joliet-Eastern Railway Company (hereafter EJE) was dismissed when the trial judge maintained exceptions to the jurisdiction. No appeal was taken from this judgment. Following the trial, U. S. Steel Corporation and Illinois Central Gulf Railroad (hereafter ICG) were dismissed. No third-party petitions were filed in the suit and only Public Belt appealed. Plaintiff did not answer the appeal nor is quantum an issue.

Public Belt contended on appeal that the trial judge erred in his finding of negligence on its part and in finding no negligence on the part of U. S. Steel or Illinois Central. The appealing defendant further claimed that plaintiff’s contributory negligence or the negligence of his fellow employees should have prevented recovery.

FACTUAL SUMMARY: THE DEFECTIVE TAILGATE

The railway car, property of EJE, was loaded with steel beams from U. S. Steel at its plant in South Chicago, Illinois. EJE then delivered the car to ICG, and the car thereafter was transported by ICG to New Orleans to the Public Belt yard there. While in the possession of Public Belt, and during the course of the unloading process, the accident occurred.

At the time, Benjamin was in the railroad car unloading the steel beams. It was his responsibility to connect clamps (described by plaintiff as “dogs”) from a crane wire to each beam, to be elevated by the crane and removed from the car. Plaintiff’s foot was seriously injured when struck by an uncontrolled beam as it was being raised a short distance by the crane, in accordance with the established procedure, so as to confirm that there was sufficient balance — the clamps having been attached — to swing the beam out of the box car. Plaintiff was alone in the car at the time and the accident was not witnessed.

The tailgate of the railroad car was not firmly secured in an upright position but was wired only partially upright. At the time the car was being unloaded, one of the two wires apparently had broken and the tailgate was leaning inward from the top at a 45° or 60° angle to the car. There were 30 or 40 I-beams in the car, some of which were sixty feet in length and stacked at the bottom of the ear and some forty feet in length and stacked on top of the longer beams. The car’s length was seventy feet.

According to Benjamin’s testimony, immediately prior to the accident the tailgate was leaning in a tilted position on an angle resting on the longer beams at the bottom of the car. After he had clamped the crane wire in the middle of one of the beams preparatory to elevation, the beam, when moved by the crane, did not elevate with balance but unexpectedly slid backward toward the tilted tailgate. One end of the beam then was caught under the tailgate thereby elevating the other end and resulting in the uncontrolled spinning of the beam causing it to strike plaintiff’s foot. According to the plaintiff’s claim, the failure on the part of one or more of defendants to see the defective condition of the tailgate and to secure it firmly in an upright position was the proximate cause of the accident.

It was stipulated by all counsel that, if ICG’s employees were called to testify, they would state that they inspected the railway car while it was under their control and no exceptions were noted, this indicating that there were no defects in the railway car and that the tailgate was secured in an upright position while it was in ICG’s possession and interchanged to Public Belt. It was further stipulated that, if inspection by ICG’s employer had revealed that the tailgate had [335]*335been leaning into the car, the car would have been chalked and the tailgate would have been wired into an upright and secure position.

In a transcript which includes somewhat confusing testimony certain facts emerge. It is clear that the tailgate was leaning on an angle inside the railway car and was not secured in an upright position. It appears equally clear that, for whatever reasons, the tailgate had been inadequately wired, rather than firmly fixed in the normal manner at the rear of the box car, and had fallen into its slanted position at some stage of the loading process or some stage of transportation.

It is apparent also that plaintiff’s injuries resulted when his foot was struck by the steel beam as it was being elevated by the crane. Because the plaintiff was the only person in a position to see what occurred when the beam struck his ankle and his testimony at the trial to some extent was inconsistent with his earlier deposition, a description of the circumstances surrounding the accident is somewhat vague. We do not infer lack of credibility with regard to Benjamin’s testimony but only a recognition of plaintiff’s inability either to express precisely what happened or to see clearly what happened.

However, it is apparent that the most logical explanation of the incident nevertheless is the one described by Benjamin: that, as the beam was being elevated a short distance, one end caught under the leaning tailgate causing it to spin out of control and to strike him.

LEGAL CONSIDERATIONS

We are confronted with the determination as to whether the defective condition of the railway car’s tailgate resulted from Public Belt’s negligence, and/or the evidence of the other defendants, whether it was a cause in fact of the accident or, conversely, whether plaintiff or his co-employees were negligent. The last of these issues may be disposed of summarily. As the trial judge obviously concluded, there simply was no specific evidence from which negligence on the part of plaintiff’s co-employees could be concluded. With regard to the remaining considerations priority should be given to the issue of plaintiff’s contended contributory negligence because, in view of the state of the law when the accident occurred, an affirmative conclusion in this regard would end all other issues.

(a) Contributory Negligence

The trial judge plainly concluded that the plaintiff was not contributorily negligent. However, the evidence relating to the circumstances surrounding the accident requires further analysis in this regard.

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Related

Louisiana Joint Underwriters of Audubon Ins. Co. v. Gant
439 So. 2d 1153 (Louisiana Court of Appeal, 1983)
Benjamin v. United States Steel Corp.
400 So. 2d 1382 (Supreme Court of Louisiana, 1981)

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Bluebook (online)
396 So. 2d 332, 1981 La. App. LEXIS 3731, Counsel Stack Legal Research, https://law.counselstack.com/opinion/benjamin-v-united-states-steel-corp-lactapp-1981.