Summary of Atlantic Coast Line R. Co. v. Daniels, Ct of App. Georgia, 1911

Relevant Facts: While one driving an automobile over three railroad tracks at a crossing PL was confined thereon by the sudden lowering of the gates, he threw his brakes on in full emergency and stopped the car, but did not change the spark and gas levers. The towerman cried to him to move the car, a train was coming, Pl released the brakes and with an abnormal degree of strength, caused by the excitement, pushed the car from the first track to the second track, whereupon the towerman told him to move the car again, that the train was coming on the middle track, which he did just in time to escape the train, and thereafter in starting his car forgot, in his excitement, the condition in which he had left the levers, and attempted to start it with the maximum power turned on, resulting in the engine “kicking back,” throwing him against the radiator, and breaking out several of his teeth, and inflicting other injuries.  a question for the jury.

Legal Issue(s): Whether the injury suffered a direct result, or proximate cause of a wrongful act by the Df ?  Whether the towerman’s acts were negligent, and such as to produce such a degree of fright in a normal person as to cause the injuries complained of.

Court’s Holding: Yes

Procedure: Judgment for plaintiff, and defendant brings error. Affirmed.

Law or Rule(s): If a man has been robbed of his power of judgment by some act not within his control, his resulting lack of judgment becomes a part of the circumstances to be considered. It is in accordance with the rule we have stated to compare his conduct with the conduct of an ordinarily prudent man under similar circumstances.

Court Rationale:  At this point the company maintains crossing bars, controlled from a signal tower located near the crossing. When the bars are up, this is a signal to the public that they may cross without danger from the trains. The plaintiff, as he approached the crossing, saw that the bars were up, indicating that the way was clear. As the approach was considerably upgrade, he threw the levers, which control the spark and the mixture of gasoline vapor admitted into the engine, into such a position as to give the machine its maximum of 18 horse power. As he came upon the tracks, the towerman suddenly lowered the bars on both sides of the crossing, thus penning him in, upon the tracks. If the negligence had not occurred, the fright would not have ensued. So, in the broad sense, the negligence was the cause of the fright.

Plaintiff’s Argument: The towerman’s actions of penning Pl w/i the crossing was negligent, and the successive negligent acts created the injury.

Defendant’s Argument: the defendant’s negligence cannot be considered as the proximate cause of the plaintiff’s injury; that the injury was not a natural or a reasonably to be anticipated effect of the defendant’s act