Case Name : Steve D. Sharpley v Metro-North Commuter Railroad
Date of Judgment : 27th March 2009
Court : U.S.D.C. - S.D. New York
Judge: District Judge Daniels
Citation : 2009 WL 855790 (S.D.N.Y.)

Background:
Plaintiff, Steve Sharpley, was a former signal inspector employed by defendant, Metro-North Commuter Railroad (“Metro North”). Sharpley filed suit under the Federal Employers’ Liability Act (“FELA”) to recover damages for injuries sustained as a result of his employer’s negligence in maintaining its premises.

Sharpley presented evidence at trial that as he was stepping down out of his employer’s truck, he placed his foot upon a heightened portion of the ground. The ground was wet from a recent snowfall and shifted under Shipley’s weight. He grabbed the steering wheel, attempting to regain his composure. He felt a pop in his back and wrenched his lower back.

Sharpley blamed the darkened conditions at the work site for his inability to see the heightened portion of ground. The trial evidence demonstrated Metro-North had previously received complaints about the inadequate lighting. Other evidence showed that Metro-North had provided Sharpley with a flashlight, which he failed to use when he alighted from the vehicle.

After a four-day jury trial, judgment was found in favor of Sharpley, who was awarded $832,403 in damages. Metro-North moved for judgment as a matter of law or, alternatively, for a new trial. Metro-North contended that the jury’s failure to find contributory negligence as well as its excessive award were against the weight of evidence and constituted a miscarriage of justice.

Sharpley’s Issue: Sharpley argued that Metro-North maintained an unsafe workplace by failing to install overhead lighting.

Metro-North’s Issue: The defense counsel stressed to the jury that the issue of lighting was irrelevant. They contended the cause of the accident was Sharpley’s failure to properly secure his footing and not slip.

Held:
The Court concluded there was sufficient evidence to support the jury’s finding that Sharpley suffered an injury solely as a result of Metro-North’s negligence in failing to provide permanent lighting fixtures.

Moreover, Metro-North’s position that the verdict must be set aside, because the jury ignored evidence that Sharpley caused the accident, stood in stark contrast to their closing arguments. There they stated the lighting conditions did not play a role in causing the accident. The jury reasonably concluded that Sharpley was unable to use a flashlight while at the same time lowering himself to the ground. Thus, the jury found that Metro-North had failed to meet its burden of proving that Sharpley was contributorily negligent. The jury’s finding that Metro-North had failed to meet its burden of proving that Sharpley was contributorily negligent was neither an error nor a miscarriage of justice.

The Court further held there was sufficient evidence to support the jury’s award. The award was consistent with evidence of Sharpley’s physical limitations caused by his back injury.

Comments:

The Court focused on what was the sole cause of Sharpley’s injury. Often a Court will find there are multiple causes of injuries. To resolve this, courts will look to the sole or primary cause of the accident. Here, the flashlight was not the sole cause of the accident. It was the lack of permanent lighting which caused the fall. It is debatable whether the flashlight would have been useful or practical as Metro-North argued. There was no debate about the need for permanent lighting, a fact that Metro-North was already aware of due to prior accidents. Thus, a flashlight would be no alternative to a permanent light fixture.

Steve Gordon