Justia Injury Law Opinion Summaries

On July 6, 2013, a train carrying crude oil derailed in Lac-Mégantic, Quebec, causing explosions that killed forty-seven people and destroyed the town center. Joe R. Whatley, Jr., as trustee for the wrongful death claimants, sued Canadian Pacific Railroad Company and related entities, alleging liability for the value of the train’s crude oil cargo.The United States District Court for the District of North Dakota found Canadian Pacific liable under the Carmack Amendment for the value of the crude oil cargo and awarded Whatley $3,950,464 plus prejudgment interest. However, the court declined to address whether the judgment reduction provision from the Montreal Maine & Atlantic Railway (MMA) bankruptcy plan applied, stating that it was a matter for the Bankruptcy Court. Canadian Pacific's motion for reconsideration was denied, leading to this appeal.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court abused its discretion by setting aside part of the joint stipulation between the parties, which required the court to decide whether the judgment reduction provision applied. The Eighth Circuit determined that the judgment reduction provision from the MMA bankruptcy plan should apply, reducing Canadian Pacific’s liability to zero, as MMA was solely responsible for the derailment.The Eighth Circuit reversed the district court’s decision and remanded the case for a complete reduction of the judgment against Canadian Pacific, ensuring that Canadian Pacific would not be held liable for more than its proportionate share of the damages, which in this case was zero due to MMA's sole liability. View "Whatley v. Canadian Pacific Railway Co." on Justia Law

Prisca Fagnon petitioned for a disorderly conduct restraining order against Ndorleh Ngaima, alleging harassment on social media, stalking, threats with a knife, and physical violence resulting in a broken nose. A temporary restraining order was issued, and a hearing was held on February 18, 2025. Both parties testified, with Fagnon presenting evidence of a physical assault by Ngaima on July 24, 2023. Ngaima denied the allegations.The District Court of Stutsman County, Southeast Judicial District, found Fagnon's testimony credible and supported by photographic evidence of her injuries. The court determined that the act of physical violence constituted disorderly conduct and issued a restraining order for two years. Ngaima appealed, arguing that the court abused its discretion by issuing the order without reasonable grounds and that the findings were inadequate.The North Dakota Supreme Court reviewed the case, noting that the standard for issuing a disorderly conduct restraining order requires reasonable grounds to believe the respondent engaged in disorderly conduct. The court found that the district court did not abuse its discretion, as the evidence of physical violence was relevant and sufficient to support the restraining order. The court also addressed the time and distance factors, concluding that the severity of the conduct and the need for controlled contact between the parties justified the order.The Supreme Court affirmed the district court's decision, holding that the findings were adequate and supported by the evidence. The court emphasized that physical violence is generally intended to adversely affect the safety, security, and privacy of another person, and the district court's credibility determinations were upheld. View "Fagnon v. Ngaima" on Justia Law

Kenya Taylor hired Los Angeles Unified School District (LAUSD) employee Tyler Martin-Brand to babysit her six-year-old son, Dayvon, during the winter break in 2019. Tragically, Martin-Brand killed Dayvon. Taylor sued LAUSD, alleging negligent hiring and supervision of Martin-Brand. A jury found in favor of Taylor, awarding her $30 million in damages. LAUSD appealed the trial court's denial of its motion for judgment notwithstanding the verdict (JNOV) and the judgment itself.The Superior Court of Los Angeles County denied LAUSD's motions for JNOV and a new trial, asserting that LAUSD was immune from liability under Education Code section 44808. The jury had found LAUSD negligent in hiring and supervising Martin-Brand, attributing 90% of the fault to LAUSD and 10% to Taylor.The Court of Appeal of the State of California, Second Appellate District, Division Three, reviewed the case. The court concluded that LAUSD was immune from liability for Dayvon’s off-campus death under Education Code section 44808, which limits school district liability for student injuries occurring off school property unless the district has specifically undertaken responsibility for the student. The court found that Dayvon’s death did not occur during any school-sponsored activity or under LAUSD’s supervision. Consequently, the court reversed the trial court's order and judgment, directing the trial court to enter judgment in favor of LAUSD. View "Taylor v. Los Angeles Unified School Dist." on Justia Law

Orlando Miguel Martínez-Ramos pleaded guilty to carjacking resulting in serious bodily injury and aiding and abetting the same, following a home invasion, robbery, and brutal physical attack on a 77-year-old woman who died nine days later. The advisory guideline sentencing range was up to fourteen years, but Martínez-Ramos acknowledged that an upward variance was warranted due to the victim's death. At sentencing, Martínez-Ramos argued for a fifteen-year sentence, while the government requested sixteen years.The United States District Court for the District of Puerto Rico did not accept either recommendation. Instead, it considered a higher advisory guideline range based on the first-degree murder cross-reference, which would have recommended a life sentence, reduced to twenty-five years due to the statutory maximum. However, the court did not apply this cross-reference, citing insufficient causation evidence and the belief that a twenty-five-year sentence was too harsh given Martínez-Ramos's youth. The court imposed an eighteen-year sentence, a substantial upward variance from the guideline range, due to the physical attack contributing to the victim's death.Martínez-Ramos appealed, arguing that the upward variance was substantively unreasonable and that the court applied too lenient a standard of causation. The United States Court of Appeals for the First Circuit reviewed the case. The court found that Martínez-Ramos had acknowledged the victim's death as a factor in his plea agreement and that the autopsy listed facial and bodily trauma as contributory factors to the death. The court concluded that the district court's finding was not clearly erroneous and affirmed the eighteen-year sentence. View "United States v. Martinez-Ramos" on Justia Law

John Ledford, an employee of Jenway Contracting, Inc., died from a fall while working. He was survived by his adult, non-dependent daughter, Summer Ledford. Unable to receive death benefits under Maryland’s Workers’ Compensation Act, Summer filed a wrongful death claim against Jenway under Maryland’s Wrongful Death Act.The Circuit Court for Baltimore County dismissed Summer’s complaint, agreeing with Jenway that the Workers’ Compensation Act limits employer liability to injured workers and their dependents, barring Summer’s claim. The Appellate Court of Maryland affirmed this decision.The Supreme Court of Maryland reviewed the case and held that the Workers’ Compensation Act’s exclusivity provision bars non-dependent adult children from pursuing wrongful death claims against a deceased employee’s employer. The court found that the Act’s exclusivity provision, which limits employer liability to the Act’s specified compensation, applies broadly and does not violate Article 19 of the Maryland Declaration of Rights. The court affirmed the judgment of the Appellate Court, maintaining that compliant employers are immune from such wrongful death suits. View "Ledford v. Jenway Contracting" on Justia Law

Amanda Watts received two vaccines, Pneumovax 23 and Boostrix, at a CVS Pharmacy in 2017. She claimed that both vaccines were negligently administered in the same improper location on her arm, leading to a chronic pain condition. However, CVS is immune from suit for the administration of Boostrix under the National Childhood Vaccine Injury Act of 1986. Consequently, Watts's complaint focused solely on the alleged negligence in administering Pneumovax.The United States District Court for the District of Maryland granted summary judgment to CVS, finding that Watts presented no evidence from which a jury could determine that her injury was caused by the Pneumovax vaccine rather than the Boostrix vaccine. The court also struck an errata sheet submitted by Watts's expert, Dr. Akhil Chhatre, which attempted to amend his deposition testimony to suggest that both vaccines contributed to Watts's injury.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The Fourth Circuit agreed that Watts failed to provide evidence to establish that her injury was caused by the Pneumovax shot, as required to overcome CVS's immunity for the Boostrix shot. The court noted that both of Watts's experts could not definitively attribute her injury to the Pneumovax vaccine alone. The court also upheld the district court's decision to strike Dr. Chhatre's errata sheet, which materially altered his original testimony.The Fourth Circuit concluded that without evidence to separate the effects of the two vaccines, a jury could only speculate on the cause of Watts's injury. Therefore, Watts could not satisfy the causation element of her negligence claim, and the summary judgment in favor of CVS was affirmed. View "Watts v. Maryland CVS Pharmacy, LLC" on Justia Law

Plaintiffs' mother was killed when a commercial truck rear-ended her car at a red light. The plaintiffs sued the truck manufacturer, Daimler Trucks North America LLC, alleging design defect and negligent design claims. They argued that Daimler Trucks should be held liable for their mother's death because it failed to equip the truck with a collision avoidance system, Detroit Assurance 4.0, which could have prevented the accident. This system warns drivers of collision risks and can autonomously stop the truck if the driver fails to act. Daimler Trucks included this system in some, but not all, of its trucks.The Superior Court of Butte County granted summary judgment in favor of Daimler Trucks, concluding that the plaintiffs' claims failed as a matter of law. The court found that the truck driver, not the truck's design, was the proximate cause of the accident and that Daimler Trucks owed no duty to install the collision avoidance system.The California Court of Appeal, Third Appellate District, reviewed the case and reversed the trial court's decision. The appellate court found that proximate cause should be a question for the jury, as a single injury can have multiple proximate causes. The court also determined that manufacturers have a general duty to install reasonable safety devices and that this duty extends to collision avoidance systems. The court rejected the trial court's conclusion that Daimler Trucks owed no duty of care and found that the plaintiffs' evidence supported the claim that the truck's design was a proximate cause of the accident.The appellate court held that Daimler Trucks must exercise due care when choosing whether to install collision avoidance systems and that the issue of whether Daimler Trucks breached that duty was outside the scope of the appeal. The court reversed the trial court's judgment against the plaintiffs and remanded the case for further proceedings. View "Ortiz v. Daimler Truck North America LLC" on Justia Law

Plaintiffs, employees and independent contractors of White Oak Radiator Service, Inc., were injured while performing work at Enable Midstream Partners, LP's natural gas processing plant. The work involved removing and replacing amine and glycol coolers. During the work, a glycol surge tank ruptured, causing injuries. Plaintiffs filed a lawsuit seeking damages for their injuries.The trial court found that the claims of Joey Miller and Davy Dowdy against Enable sounded in tort rather than workers' compensation. The court awarded damages to Mr. Dowdy for injuries to his cervical spine and hearing loss, but found that White Oak bore a greater percentage of fault than assigned by the trial court. The trial court assigned 90 percent fault to Enable and 10 percent to White Oak. Enable appealed, arguing that the plaintiffs' exclusive remedy was under the Louisiana workers' compensation laws and challenging the allocation of fault and damages.The Supreme Court of Louisiana reviewed the case and held that the manual labor exception under La. R.S. 23:1021 (7) does not apply to the employees and independent contractors of an independent contractor. Therefore, plaintiffs' claims against Enable sound in tort. The court found no manifest error in the trial court's award of damages to Mr. Dowdy for his cervical spine injuries and hearing loss. However, the court found that the trial court erred in the apportionment of fault and amended the judgment to assign 70 percent fault to Enable and 30 percent fault to White Oak. The trial court's judgment was affirmed as amended. View "McBride v. Old Republic Insurance Co." on Justia Law

Brenda Zaragoza fell in the parking lot of a Johnson County public library, resulting in serious injuries. She sued the Johnson County Board of Commissioners, alleging negligence for failing to mitigate the presence of a storm drain and warn of the change in elevation between the curb and the parking surface. The district court granted summary judgment for the County, citing recreational use immunity under the Kansas Tort Claims Act (KTCA), which bars negligence claims arising from the use of public property intended for recreational purposes unless gross and wanton negligence is involved. The court also denied Zaragoza's motion to amend her petition to add a claim of gross and wanton negligence.The Kansas Court of Appeals affirmed the district court's decision, holding that the library's recreational use immunity applied and that the district court did not abuse its discretion in denying Zaragoza's untimely motion to amend her petition. Zaragoza then petitioned for review, raising both issues. After the petition was granted, she filed a supplemental brief raising a new constitutional argument, which was not considered because it was not presented in her petition for review or before the lower courts.The Kansas Supreme Court upheld the lower courts' decisions. The court declined to consider Zaragoza's unpreserved constitutional challenge. It affirmed the district court's grant of summary judgment, agreeing that the library's parking lot fell under the recreational use immunity provision of the KTCA. The court also affirmed the district court's denial of Zaragoza's motion to amend her petition, finding no evidence of gross and wanton negligence by the County. The court concluded that the library is public property intended for recreational purposes and that the parking lot is integral to its function, thus qualifying for immunity under the KTCA. View "Zaragoza v. Board of Johnson County Comm'rs " on Justia Law

During Winter Storm Uri in February 2021, extreme weather conditions in Texas led to record electricity demand and severe power shortages. The Electric Reliability Council of Texas (ERCOT) declared a "Level 3 Emergency" and ordered transmission and distribution utilities (the "Utilities") to cut power to some customers, resulting in widespread outages. Plaintiffs alleged that the Utilities' actions during the storm, including failing to rotate blackouts and cutting power to critical infrastructure, worsened the crisis and violated common-law duties.The plaintiffs filed numerous lawsuits against various participants in the Texas electricity market, including the Utilities, asserting claims of negligence, gross negligence, and nuisance. The cases were consolidated into a multidistrict litigation pretrial court, which dismissed some claims but allowed the gross-negligence and intentional-nuisance claims against the Utilities to proceed. The Utilities sought mandamus relief from the court of appeals, which granted partial relief by dismissing some claims but allowing the gross-negligence and intentional-nuisance claims to continue.The Supreme Court of Texas reviewed the case and held that the plaintiffs' pleadings did not sufficiently allege that the Utilities "created" or "maintained" a nuisance, leading to the dismissal of the intentional-nuisance claims with prejudice. The court also found that the pleadings were insufficient to support gross-negligence claims but allowed the plaintiffs an opportunity to replead these claims in light of the court's guidance. The court conditionally granted mandamus relief, ordering the trial court to vacate its previous order and dismiss the intentional-nuisance claims while permitting the plaintiffs to amend their gross-negligence claims. View "IN RE ONCOR ELECTRIC DELIVERY CO. LLC" on Justia Law