CSX Transportation, Inc. v. CRH Americas, Inc.

CourtDistrict Court, W.D. North Carolina
DecidedJuly 9, 2025
Docket3:21-cv-00480
StatusUnknown

This text of CSX Transportation, Inc. v. CRH Americas, Inc. (CSX Transportation, Inc. v. CRH Americas, Inc.) is published on Counsel Stack Legal Research, covering District Court, W.D. North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
CSX Transportation, Inc. v. CRH Americas, Inc., (W.D.N.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA

AT CHARLOTTE CSX TRANSPORTATION, INC., Plaintiff, v. CIVIL ACTION NO. 3:21-cv-00480 BONSAL AMERICAN, INC. formerly known as Oldcastle Retail, Inc., OLDCASTLE BUILDING PRODUCTS INC. formerly known as Oldcastle Retail, Inc., OLDCASTLE LAWN & GARDEN, INC., JOHN DOES 1-10, and ABC CORPORTATIONS 1-10 Defendants. MEMORANDUM OPINON AND ORDER Pending are Defendants Bonsal American, Inc., Oldcastle Building Products Inc., and Oldcastle Lawn & Garden, Inc.’s (“Defendants”) (1) Renewed Motion to Exclude Certain Opinions and Testimony of Gary Wolf, [ECF 132, 133], (2) Renewed Motion to Exclude Certain Opinions and Testimony of Timothy Siegel, [ECF 134, 135], and (3) Renewed Motion to Exclude Certain Opinions and Testimony of Michael Ports, [ECF 145, 146], all filed on November 22, 2024. On the same date, Plaintiff CSX Transportation, Inc. (“CSX”) filed its (1) Motion to Exclude the Reports and Testimony of Alan Pagels, Charles Culver, and Robert Gentry [ECF 136, 137], (2) Motion to Exclude the Report and Testimony of Francisco Godoy [ECF 138, 139], and (3) Motion to Exclude the Reports and Testimony of Christopher Lewis. [ECF 140, 141]. The parties have responded in opposition and replied accordingly. The matter is ready for adjudication. I.

On September 10, 2021, CSX instituted this action, asserting claims of negligence, negligence per se, res ipsa loquitor, trespass, nuisance, and unjust enrichment. [ECF 1]. CSX sought damages for injuries resulting from the alleged claims. [Id. at ¶ 24]. On September 9, 2023, Defendants filed a Motion for Summary Judgment and motions to strike the opinions and testimonies of certain experts. [ECF 64, 67, 66, 74]. On the same date, CSX filed a Motion for Partial Summary Judgment and motions to strike experts. [ECF

69, 72, 77, 79]. Both CSX and Defendants filed timely responses and replies to all pending motions. In its briefing, CSX voluntarily dismissed its claims for res ipsa loquitor and unjust enrichment. [ECF 94 at 4 n.2]. Additionally, Defendants expressed their intent to withdraw their Motion to Strike Mazzanti testimony. [ECF 102 at 18]. On December 19, 2023, the Court held oral argument regarding the motions for summary judgment. [ECF 110]. On September 30, 2024, the Court granted in part and denied in part the parties’ cross-motions for summary judgment. [ECF 124; see as amended ECF 126]. The Court denied summary judgment on the negligence claim, finding sufficient evidence for a jury to determine if Defendants owed a duty of care in operating its water management system and whether that duty

was breached. [See generally ECF 126]. Regarding the trespass claim, the Court concluded CSX “put forth sufficient facts from which a reasonable jury could find Defendants either intentionally or negligently caused water to exit their property and enter Plaintiff’s right of way.” [Id. at 17]. Regarding the nuisance claim, Defendants were awarded summary judgment as the alleged injury arose from a single incident rather than an ongoing event. [See generally id. at 18-19]. Additionally, the Court denied summary judgment on the negligence per se claim, finding extant genuine and material factual issues regarding whether the water impounded the Stockpile areas and whether the facilities were exempted from jurisdiction under the Dam Safety Law. [See generally id. at 19-23].

Moreover, the Court declined to limit CSX's damages to fair market value, finding a jury should (1) determine if a market exists for the destroyed locomotives, and (2) consider other evidence in determining damages. [See generally id. at 23-27]. The Court also concluded some contributory negligence theories were preempted, while others could proceed. Theories related to CSX's train operations and scheduling were preempted, while claims about failure to conduct studies or certain inspections were not preempted. [Id.]. Notably, the Court declined to limit damages to a strict fair market value calculation. [Id. at 27]. In sum, the negligence, negligence per se, and trespass claims will proceed to trial. At summary judgment, the Court denied without prejudice the then-pending

motions regarding experts to “[permit] the parties to refile these motions [and] ensure that the parties and the Court have the benefit of full briefing in the context of the narrowed case and the issues that remain.” [ECF 126 at 47]. The motions described at the outset thus now require adjudication, after having been fully briefed. On May 9, 2025, the Court granted Defendants’ Motion to Seek Leave to Rebut the Ports Declaration and to Offer Expert Testimony on the Fair Market Value of CSX's Locomotives, [ECF 142], scheduled the trial for August 4, 2025, and established the remaining obligations and deadlines for the parties in preparation for trial. [ECF 171]. II.

Federal Rule of Evidence 702 “imposes a special gatekeeping obligation on the trial judge to ensure that an expert's testimony both rests on a reliable foundation and is relevant to the task at hand.” United States v. Hunt, 99 F.4th 161, 180 (4th Cir. 2024) (quoting Sardis v. Overhead Door Corp., 10 F.4th 268, 281 (4th Cir. 2021) (cleaned up)); see also Kumho Tire Co. v. Carmichael, 526 U.S. 137, 152, (1999); Daubert v. Merrell Dow Pharms., 509 U.S. 579, 597 (1993). To be deemed admissible, Rule 702 requires the expert's testimony “will help the trier of fact.” Fed. R. Evid. 702(a). Notably, effective December 1, 2023, Rule 702 was amended. In a report to the Judicial Conference Committee on Rules of Practice and Procedure, the Advisory

Committee pinpointed common mistakes the amendments purport to address: [T]he Committee resolved to respond to the fact that many courts have declared that the reliability requirements set forth in Rule 702(b) and (d) --- that the expert has relied on sufficient facts or data and has reliably applied a reliable methodology --- are questions of weight and not admissibility, and more broadly that expert testimony is presumed to be admissible. These statements misstate Rule 702, because its admissibility requirements must be established to a court by a preponderance of the evidence.

See Advisory Comm. on Evidence Rules, Report to the Standing Comm. on Rules of Practice & Procedure, (May 15, 2022), https://www.uscourts.gov/sites/default/files/evidence_rules_report_- _may_2022_0.pdf. Moreover, these revisions were intended merely to “clarify and emphasize that expert testimony may not be admitted unless the proponent demonstrates to the court that it is more likely than not that the proffered testimony meets the admissibility requirements set forth in the rule.” Fed. R. Evid. 702 advisory committee’s note to 2023 amendment. Thus, the amendment aims to highlight the burden of proof and admissibility standards—not to drastically alter them. Federal Rule of Evidence 702 is applied in tandem with Daubert when courts consider the parties’ challenges to expert testimony. In Daubert, the Supreme Court observed the admissibility of scientific evidence was no longer cabined by knowledge or evidence “generally accepted” as reliable in the relevant scientific community. Daubert, 509 U.S. at 588-89.

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CSX Transportation, Inc. v. CRH Americas, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/csx-transportation-inc-v-crh-americas-inc-ncwd-2025.