Negligence- Federal Railroad Administration (FRA) Track Safety Standards

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7^th Circuit Court of Appeals

Case Name: Martin Jaranowski v. Indiana Harbor Belt Railroad Company

Case No.: 22-2437

Officials: Hamilton, Jackson-Akiwumi, and Lee, Circuit Judges.

Focus: Negligence- Federal Railroad Administration (FRA) Track Safety Standards

Jaranowski had been employed as a conductor for the Railroad for a span of 22 years. In 2020, while operating a railroad switch, he sustained a severe neck injury. In response, he initiated legal proceedings against the railroad under the Federal Employers’ Liability Act (FELA), specifically citing that his injury resulted from the railroad’s failure to adequately maintain the switch. Jaranowski accused the railroad of both ordinary negligence and negligence per se, basing his claims on alleged violations of the Federal Railroad Administration (FRA) Track Safety Standards outlined in 49 C.F.R. 213. However, the district court determined that Jaranowski had not provided sufficient evidence to support the conclusion that the railroad had prior knowledge or awareness, either actual or constructive, of any defect in the switch prior to the occurrence of his injury. As a result, the court granted the railroad summary judgment.

The decision was subsequently reversed by the Seventh Circuit Court of Appeals. While it is indeed a requirement to establish actual or constructive notice to violate the federal Track Safety Standards, Jaranowski presented compelling evidence that created a genuine dispute as to whether the railroad should have been aware of the defective condition of the switch before his injury took place. Taking into consideration Jaranowski’s factual account and the expert report from the individual who examined the switch, a reasonable jury could potentially reach the conclusion that the railroad’s prior inspection was carried out without the necessary degree of care.

Reversed and Remanded.

Decided 07/05/23

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