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Personal Injuries and Dirty Bathrooms – Edwards v. CSX Transp. Inc.

train accidentWhen we think about personal injury cases and negligence lawsuits, we typically imagine slip and fall accidents, car crashes, and faulty railings.  But personal injuries can arise in virtually in any situation, even in the most unpredictable of conditions. A recent case out of the Sixth Circuit Court of Appeals takes a look at personal injuries arising from dirty bathrooms on a train moving from North Carolina to Tennessee. Despite the best efforts of the plaintiff, a train engineer, the Sixth Circuit held that there are limits to federal government liability for the unpleasant conditions in public restrooms.

In Edwards v. CSX Transp., Inc., Edwards was a train engineer working for CSX.  On the morning of May 28, 2012, he boarded a train headed to Tennessee with an upset stomach.  After rushing quickly to the bathroom, Edwards was dismayed to find that it was, in his words, “nasty.” Unwilling to use the toilet, which he alleged was splattered with various substances, Edwards rushed outside to a catwalk along the side of the train and attempted to throw up over the side. In the process, he fell over the handrail and off the catwalk, landing on the ground below. He broke several bones and walked away with lasting injuries.

Edwards eventually sued CSX under the Federal Employers’ Liability Act and general negligence claims, arguing that federal statutes required CSX to keep its train bathrooms in good sanitary condition. According to Edwards, had the bathroom not been so foul, he would not have been forced to throw up outside the train and would not have injured himself. In response, CSX stated that it had complied with the federal statutes, including performing an inspection of the bathroom just the day before Edwards was hurt. The district court agreed, finding that CSX had complied and that this compliance precluded liability for Edwards’ injuries.

Under the Federal Employers’ Liability Act, any person who is injured while working for an interstate railroad can only sue for injuries under the FELA. Under the FELA, a railroad may be held liable if it fails to comply with federal statutes and rules governing its conduct, including, as here, the requirement under 49 U.S.C. 229.139 that locomotives be inspected regularly and that the bathrooms in lead locomotives be kept in a sanitary condition.  Under the rules, the duty to remedy an unsanitary bathroom arises only upon inspection of the locomotive, and dirty conditions that arise during transport only need be remedied at the next inspection.

The Sixth Circuit concluded that CS had conducted a daily inspection of the train before Edwards’ injury, had cleaned the bathroom, and had not found anything wrong with the bathroom at that time. Accordingly, CSX had complied with the regulations by conducting an inspection, even if, later that day, the bathroom did become too dirty for Edwards to use.

The Sixth Circuit’s decision serves as a good reminder and warning that personal injury claims against government entities, or private entities regulated by federal law, can require a careful review of federal regulations and rules that may apply. If you have recently been a victim of an accident involving a train or federal vehicle, knowledgeable personal injury attorney Eric Beasley can help you evaluate whether any federal statutes or rules are likely to have an impact on your claim. For more information or to discuss the circumstances of your case, contact the Law Office of Eric Beasley today at 615-859-2223.

Related Blog Posts:

Direct and Vicarious Liability in Tennessee – Can Employers Be Held Liable for Both?, Tennessee Personal Injury Blog, April 20, 2016

Government Liability in Tennessee for Automobile Accidents Involving Police Officers, Tennessee Personal Injury Blog, April 13, 2016.

Can Tennessee Emergency Vehicles Be Held Liable for Accidents That Occur While On Emergency Calls?, Tennessee Personal Injury Blog, February 10, 2016.