Anne Payne v. CSX Transportation, Inc.

Tenn. Ct. App.December 27, 2013No. E2012-02392-COA-R3-CV

RemandedCSX Transportation, Inc.$3,200,000 at issue

Facing something similar at work?Check your rights — free, private, no sign-up

Case Details

Judge(s): Presiding Judge Charles D. Susano, Jr.
Status — whether other courts must follow this ruling: Published
Procedural Posture — the stage the case had reached: Appeal from summary judgment and new trial order; case remanded

Related Laws

No specific laws identified for this ruling.

Outcome

Appellate court reversed summary judgment and new trial order, holding that trial court erred in sua sponte instructing jury on negligence per se after verdict was rendered, and in excluding expert causation testimony. Case remanded for proper proceedings.

Excerpt

Winston Payne brought this action against his former employer, CSX Transportation, Inc., under the Federal Employers' Liability Act ("FELA"), alleging that CSX negligently exposed him to asbestos, diesel fumes, and radioactive materials in the workplace causing his injuries. The jury returned a verdict finding (1) that CSX negligently caused Payne's injuries (2) that CSX violated the Locomotive Inspection Act or safety regulations regarding exposure to asbestos, diesel fumes, and radioactive materials and (3) that Payne's contributory negligence caused 62% of the harm he suffered. The jury found that "adequate compensation" for Payne's injuries was $8.6 million. After the jury returned its verdict, the trial court, sua sponte, instructed the jury, for the first time, that, under FELA, its finding that CSX violated a statute or regulation enacted for the safety of its employees meant that plaintiff would recover 100% of the damages found by the jury. The court sent the jury back for further deliberations. It shortly returned with an amended verdict of "$3.2 million @ 100%." Six months after the court entered judgment on the $3.2 million verdict, it granted CSX's motion for a new trial, citing "instructional and evidentiary errors." The case was then assigned to another trial judge, who thereafter granted CSX's motion for summary judgment as to the entirety of the plaintiff's complaint. The second judge ruled that the causation testimony of all of plaintiff's expert witnesses was inadmissible. We hold that the trial court erred in instructing the jury, sua sponte, on a purely legal issue, i.e., that the jury's finding of negligence per se under FELA precluded apportionment of any fault to the plaintiff based upon contributory negligence, an instruction given after the jury had returned a verdict that was complete, consistent, and based on the instructions earlier provided to it by the trial court. We further hold that, contrary to the trial court's statements, the cou

What This Ruling Means

**Railroad Worker Wins Right to New Trial in Toxic Exposure Case** Winston Payne, a railroad worker, sued his former employer CSX Transportation after developing injuries he claimed were caused by exposure to asbestos, diesel fumes, and radioactive materials at work. A jury awarded Payne $3.2 million, finding that CSX was negligent and violated safety laws regarding toxic workplace exposure. However, the trial court made significant errors during the proceedings. The judge improperly gave the jury additional legal instructions after they had already reached their verdict, and wrongly excluded expert witness testimony about what caused Payne's injuries. CSX appealed the verdict. The appellate court sided with the procedural concerns, ruling that the trial court had made serious mistakes. The court reversed the trial court's decisions and sent the case back for new proceedings to be conducted properly. **Why This Matters for Workers:** This case shows that railroad workers can successfully sue their employers under federal law for toxic exposure injuries. Even when courts make procedural errors that benefit workers, those mistakes can lead to appeals and delays. The case demonstrates the importance of having proper expert testimony to prove that workplace exposures caused health problems, and that following correct legal procedures protects workers' rights in the long run.

This summary was generated to explain the ruling in plain English and is not legal advice.

Similar Rulings

Read Full Opinion More CSX Transportation, Inc. Rulings All Rulings

Facing something similar at work?

Court rulings like this one are useful, but every situation is different. Take 2 minutes to see which laws may protect you — it's free, private, and no account is required to start.

Check My Rights Learn the Basics

This ruling information is sourced from public court records via CourtListener.com. Case outcomes, claim types, and summaries are extracted using AI analysis and may be incomplete or inaccurate. It is provided for informational and educational purposes only and does not constitute legal advice.

See something wrong, or named in this ruling and want it corrected or redacted? Request a correction.