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Railroad Not Liable for Disgusting Bathroom, Tragic Puking

By Casey C. Sullivan, Esq. on May 10, 2016 | Last updated on March 21, 2019

Ricky Edwards worked for CSX Transportation for 31 years before his career was ended by a freak accident -- caused in part by a "nasty" toilet. When Edwards showed up to work with an upset stomach one day, his nausea was only exacerbated by the foul conditions in his train's bathroom: urine, feces, and "blue chemical" splattered all over the toilet.

When his nausea escalated, Edwards chose to ralph over the rails, rather than in the foul toilet. In the process, he fell from the train, breaking his back and ending his career with CSX. And that wasn't the end of the gut-retching news for Edwards, whose suit against CSX was tossed by the Sixth Circuit last Friday.

A Real Crappy Situation

Ricky Edwards already felt sick to his stomach when he showed up for work CSX on May 28, 2012. The bathroom in his locomotive didn't help, covered as it was with filth and excrement, across the floor and toilet bowl. So when Edwards couldn't hold back his nausea six hours later, he puked over the side of the train -- a fairly reasonable alternative to the vomit-inducing bathroom. Mid-expurgation, Edwards took a tumble, falling from the train and experiencing career-ending injuries.

Edwards sued for damages, arguing that federal regulations required CSX to keep its bathrooms clean. A sanitary bathroom would have meant a safe place to spew, Edwards argued, and thus CSX was liable for his injuries.

Federal Railroad Bathroom Regulations 101

The Federal Employers' Liability Act provides the exclusive right of action for any person who suffers an injury while employed by an interstate railroad. Because Edwards had abandoned a general negligence theory of liability under the Act, he was limited to arguing negligence per se, for CSX's alleged violation of federal regulations governing railroad bathroom cleanliness, the Sixth Circuit noted.

And indeed, there are such regulations. Under the Locomotive Inspection Act, railroad companies must keep their trains "in proper condition and safe to operate," with regular inspection. Under federal regulations implementing the act, bathrooms in the front of the train must be sanitary, in working order, and inspected daily. From Edwards' description, CSX's bathrooms were anything but sanitary.

But, as the Sixth Circuit determined, the duty to remedy an unsanitary bathroom arises "only at the daily inspection." CSX had inspected the bathroom the day before and wasn't required to inspect it again until the evening of the 28th, hours after Edwards's injuries. When CSX inspected, the bathroom was sanitary and in working order. It was only after inspection that some evil defecator destroyed the toilet -- and, afterwards, Edwards' career.

Thus, because CSX met its regulatory requirements, Edwards could not show negligence per se, the court ruled. And with that, his case was chucked out, like so much egesta.

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