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Law School Case Brief

Sheehan v. St. Paul & D. R. Co. - 76 F. 201 (7th Cir. 1896)


The railroad company has the right to a free track apart from public crossings; it is not bound to any act or service in anticipation of trespassers thereon; and the trespasser who ventures to enter upon a track for any purpose of his own assumes all risks of the conditions which may be found there, including the operation of engines and cars.


Plaintiff Sheehan was injured when he became entangled in railroad track owned by defendant St. Paul & D. R. Co. ("St. Paul") and was thereafter struck by train. Sheehan filed a lawsuit against St. Paul in federal district court seeking to recover damages for his injuries. The undisputed evidence established that, at the time of his injury, Sheehan was a trespasser on St. Paul's tracks. The trial court directed a verdict for St. Paul, and Sheehan appealed.


Was St. Paul liable to Sheehan for the injuries that he sustained?




On appeal, the court affirmed the trial court's judgment. The court ruled that Sheehan was a trespasser who ventured upon a track for a purpose of his own and assumed all risks of conditions which were found there, including operation of engines and cars. The obligation of St. Paul was to make all reasonable effort to avert injuries that could be controlled. There was no evidence to weaken the force of statements furnished by engineer, fireman, and brakeman, declaring that in spite of every means used to stop the train by exerting their utmost effort immediately upon hearing the Sheehan's cry, the train could not be stopped in time because of the conditions at the time, such as slippery state of the rails and the inability of using sand to slow the train.

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