Amtrak Not Liable for Mysterious Passenger Death, Says 8th Cir.
The Eighth Circuit affirmed a lower court's finding that Amtrak was not liable in a wrongful death action brought by the deceased's estate. His son sued Amtrak on theories of negligence when Mr. Haukeroid's body was found near the rails of the Amtrak line, although the exact nature of his exiting the vehicle remained a mystery.
The case also touches on the issue of due care owed to passengers in common carrier vehicles.
The deceased in this case is Mr. Andrew Haukeroid. Mr. Haukeroid boarded a train in San Antonio, Texas en route to Chicago, Illinois to visit his sons. While on the train, Haukeroid spoke to his sons on and off via cell phone throughout the day from about 3:00 p.m. till about 10:00 p.m. late at night. The train trip was scheduled to last until noon the next day.
The facts are blurry, but it appears that Mr. Haukeroid somehow exited the train and perished by the train tracks somewhere in Clay County, Arkansas. The doors had not been unsecured and no evidence was provided that would support some sort of foul play. A passenger and other witnesses provided testimony that Haukeroid was not in his right mind during at least part of the trip, and it came to light that the family had been worried in times past that Haukeroid worried that he suffered possible dementia.
Haukeroid's son Sam sued Amtrak, alleging negligence. Amtrak moved for summary judgment and was granted relief by the district court. Appeal followed.
Haukeroid's son contended that Amtrak negligently caused his father's death and pushed several theories. One, he argued that Amtrak was negligent because it did not install an indicator that would have alerted employees that the door had been opened. Second, Amtrak was negligent for not more vigilantly watching Haukeroid despite his alleged mental illness.
The court would not hear the argument as to Amtrak's alleged negligence as to the alarms. Negligence claims must prove but for cause and proximate and foreseeable causation. In this particular case, the Eighth Circuit determined that Amtrak's failure to install status indicators in the doors did not and couldn't have prevented Haukeroid's death. At most, it would have simply alerted the crew as Haukeroid fell out the door. So, the issue of actual causation was settled against Haukeroid.
Also, assuming arguendo that Amtrak had a duty to secure the doors better, Haukeroid's estate did not show that the lack of additional safety features were a proximate cause of Andrew's exiting the train.
As to the argument that Amtrak should have vanguarded Haukeroid better? The circuit found that the crew could not have understood, given the facts, that Haukeroid was confused or somehow impaired cognitively.
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