Saunders v. Union Pac. R.R. Co.

New Mexico Court of Appeals·Decided May 12, 2025·Unpublished

Opinion

The slip opinion is the first version of an opinion released by the Clerk of the Court of Appeals. Once an opinion is selected for publication by the Court, it is assigned a vendor-neutral citation by the Clerk of the Court for compliance with Rule 23-112 NMRA, authenticated and formally published. The slip opinion may contain deviations from the formal authenticated opinion. 1 IN THE COURT OF APPEALS OF THE STATE OF NEW MEXICO

2 Opinion Number: ______________

3 Filing Date: May 12, 2025

4 No. A-1-CA-41379

5 GARY A. SAUNDERS,

6 Plaintiff-Appellee,

7 v.

8 UNION PACIFIC RAILROAD COMPANY,

9 Defendant-Appellant.

10 APPEAL FROM THE DISTRICT COURT OF BERNALILLO COUNTY 11 Nancy J. Franchini, District Court Judge

12 Mendez Isaac Joudi, PLLC 13 Joseph G. Isaac 14 Tiffany N. Joudi 15 El Paso, TX

16 L. Helen Bennett, PC 17 L. Helen Bennett 18 Albuquerque, NM

19 for Appellee

20 Hall & Evans, LLC 21 Cari Neill 22 Gina M. Rossi 23 Denver, CO 1 Haynes and Boone, LLP 2 Kent Rutter 3 Ryan Pitts 4 Houston, TX

5 for Appellant 1 OPINION

2 YOHALEM, Judge.

3 {1} Defendant Union Pacific Railroad Company (Union Pacific) appeals a jury

4 verdict awarding damages to Plaintiff Gary A. Saunders, a Union Pacific employee

5 who was assaulted by coworker Eric Magoon while both were working at a jobsite

6 near Deming, New Mexico. The Federal Employers’ Liability Act (FELA), 45

7 U.S.C. §§ 51-60, provides the exclusive remedy for the death or injury of a railroad

8 employee caused by the negligence of the employer railroad. A railroad is liable

9 under the FELA for injuries to its employee from the intentional tort of a coworker

10 if the railroad was negligent under either a respondeat superior or a direct negligence

11 theory. The jury found Union Pacific negligent, and awarded Plaintiff substantial

12 damages for the injuries caused by Magoon’s assault. Union Pacific asks this Court

13 to set aside the verdict, and order a new trial, contending that (1) there was

14 insufficient evidence that Union Pacific was negligent; (2) the jury instructions

15 incorrectly stated the governing law; (3) the jury instruction on Plaintiff’s theory of

16 liability included negligent supervision and negligent training claims that were not

17 supported by substantial evidence; (4) the jury instruction on damages, by including

18 an instruction on aggravation of a preexisting condition, allowed for double recovery

19 of noneconomic damages; and (5) the damages awarded by the jury were excessive.

20 Alternatively, Union Pacific argues that (1) the FELA, 45 U.S.C. § 55, and the 1 collective bargaining agreement, require that the amounts paid by Union Pacific for

2 Plaintiff’s medical bills be offset from the judgment; and (2) the amounts subject to

3 the liens of the Railroad Retirement Board (RRB) and of an insurer should also be

4 offset from the judgment. We remand solely to allow the district court to determine

5 and offset the amount required by the terms of the collective bargaining agreement,

6 and otherwise affirm.

7 BACKGROUND

8 {2} Plaintiff was an assistant foreman employed by Union Pacific. In April 2012,

9 Plaintiff’s work group (gang) were performing maintenance work on railroad tracks

10 near Deming. Plaintiff’s gang used an MS-60 car, a type of specialized vehicle for

11 transporting waste rock and debris generated by track maintenance. Every morning

12 before work began for the day, foremen and supervisors met in an empty bus parked

13 at the worksite to coordinate the day’s work.

14 {3} On April 13, 2012, Plaintiff was present at a morning meeting with a dozen

15 Union Pacific employees, including Magoon, who was the supervisor of the

16 mechanic team. Plaintiff told Magoon that he needed repairs on his gang’s MS-60

17 car—a request that Plaintiff had been making for two months, and which had not

18 been fulfilled by Magoon. As Plaintiff began to explain that the condition of the

19 MS-60 car was a safety issue, Magoon struck Plaintiff multiple times with his fist

20 on Plaintiff’s hard hat. Although Plaintiff suffered no immediate pain, he developed

2 1 neck pain and ten days later sought medical attention. Plaintiff was admitted to a

2 hospital for treatment; his injuries ultimately required surgery. Plaintiff reported the

3 incident and his injuries to Union Pacific. Medical testimony at trial corroborated

4 Plaintiff’s report that his injuries were due to Magoon’s assault. We incorporate

5 further factual discussion into our analysis of the sufficiency of the evidence.

6 DISCUSSION

7 I. Federal Law Governs a Railroad’s Liability Under the FELA for Injuries 8 to an Employee Caused by the Intentional Tort of a Coworker

9 {4} Plaintiff brought his cause of action under the FELA. Federal law provides

10 that “damages for the death or injury of a railroad employee engaged in interstate

11 commerce, allegedly caused by the negligence of the railroad, are recoverable

12 exclusively from the railroad under the FELA, and may not be recovered under state

13 law.” Janelle v. Seaboard Coast Line R.R., 524 F.2d 1259, 1261 (5th Cir. 1975).

14 What constitutes negligence under the FELA is a federal question, and federal court

15 precedent construing and applying the FELA governs. See Urie v. Thompson, 337

16 U.S. 163, 174 (1949).

17 {5} When a railroad worker claims injury caused by the intentional tort of a

18 coworker under the FELA, as Plaintiff does in this case, the railroad employer is

19 liable only if the employer was negligent under either “a respondeat superior or a

20 direct negligence theory.” See Mullahon v. Union Pac. R.R., 64 F.3d 1358, 1362 (9th

3 1 Cir. 1995) (emphasis omitted). The jury in this case was instructed on both theories

2 of negligence.

3 {6} A railroad may be found liable for negligence under a respondeat superior

4 theory if the plaintiff was intentionally assaulted by an employee of the railroad who

5 was acting within the scope of their employment at the time of the assault, and if that

6 employee’s conduct was, to any extent, “in furtherance of the [railroad]’s business.”

7 Id. (internal quotation marks and citation omitted). Alternatively, a railroad

8 employer may be found “directly negligent” under the FELA for its employee’s

9 intentional assault if it knew or should have known of the employee’s propensity to

10 commit such assaults and should reasonably have made reasonable provision against

11 such misconduct. See Harrison v. Mo. Pac. R.R., 372 U.S. 248, 249 (1963). The

12 railroad employer need not be able to foresee the “exact manner” of the injury, but

13 only that “that an injury might occur.” Mullahon, 64 F.3d at 1364 (internal quotation

14 marks and citations omitted). As the United States Supreme Court has stated, “[T]he

15 fact that the foreseeable danger [to the railroad’s employee] was from intentional or

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