Pokora v. Wabash Railway Co.
292 U.S. 98 (1934)
Case Summary
(Negligence Law)
FACTS:
Pokora, the plaintiff, was driving a truck and approached a railroad crossing where his view of the tracks was obstructed. He stopped, listened, but did not exit his vehicle to look down the tracks. Believing it was safe, he proceeded and was struck by a train operated by the defendant, Wabash Railway Co. Pokora claimed the railroad was negligent for failing to provide adequate warning signals. The lower courts ruled in favor of the railroad, based on a standard that required drivers to look and listen, including potentially leaving their vehicles if visibility was obstructed.
RELEVANT LAW:
The Court examined negligence principles, particularly whether the "stop, look, and listen" rule applied to all railroad crossings or if situational factors could alter a driver's duty of care.
ISSUE:
The key legal issue was whether the standard of care in approaching a railroad crossing required Pokora to get out of his truck and physically look down the tracks, or whether stopping, listening, and proceeding when it seemed safe was reasonable under the circumstances.
JUDGEMENT:
In Pokora v. Wabash Railway Co., the U.S. Supreme Court reversed the lower court’s judgment, holding that the question of negligence should be decided by a jury, not by a rigid rule. The Court found that the standard of care at railroad crossings should not be based on an inflexible "look and listen" rule, especially when a driver’s view is obstructed.
The Court emphasized that negligence is determined by the circumstances of each case, not by fixed formulas. In this case, the plaintiff, Pokora, stopped his truck, listened for an approaching train, and proceeded when he heard nothing. The Court ruled that this action was reasonable under the specific circumstances, and it was not required for him to get out of the vehicle to inspect the tracks.
The Court also rejected the idea that there is a mandatory rule requiring drivers to physically exit their vehicles when visibility is obstructed. It held that the question of whether Pokora acted reasonably should be left to the jury, as it involved an evaluation of the facts, including the obstructed view and the precautions he took.
Thus, the Court’s decision reinforced the principle that negligence should be assessed based on the facts of the case and that juries, not judges, should determine whether a defendant’s or plaintiff’s conduct was reasonable.
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