Fairport, Painesville & Eastern R. Co. v. Meredith - 292 U.S. 589 (1934)
U.S. Supreme Court
Fairport, Painesville & Eastern R. Co. v. Meredith, 292 U.S. 589 (1934)
Fairport, Painesville & Eastern Railroad Co. v. Meredith
Argued May 4, 7, 1934
Decided June 4, 1934
292 U.S. 589
1. The requirement of the Safety Appliance Act that trains shall be equipped with power brakes implies that such brakes shall be maintained for use. P. 292 U. S. 593.
2. The title of an act and the history leading up to its adoption, as aids to statutory construction, are to be resorted to only for the purpose of resolving doubts as to the meaning of the words used in the act in case of ambiguity. P. 292 U. S. 594.
3. Power brakes are required by the Safety Appliance Act for the safety not only of railway employees and passengers on trains, but also of travelers on the highways at railway crossings. P. 292 U. S. 594.
4. It fairly may be said that the nature of the duty imposed by a statute and the benefits resulting from its performance usually determine what persons are entitled to invoke its protection. P. 292 U. S. 596.
5. The Safety Appliance Act imposes absolute duties upon interstate railway carriers, and thereby creates correlative rights in favor of such injured persons as come within its purview; but the right to enforce the liability which arises from the breach of duty is derived from the principles of the common law. P. 292 U. S. 598.
6. The doctrine of last clear chance amounts, in effect, to a qualification of the rule of contributory negligence, having the result of relieving the injured person from the consequences of his violation of that rule, and its application in a grade crossing case in a state court on the assumption that the accident might have been avoided, notwithstanding the contributory negligence, if power brakes had been maintained as prescribed by the Federal Safety Appliance Act, is a matter of local law. P. 292 U. S. 598.
46 Oh.App. 457, 189 N.E. 10, affirmed.
Certiorari, 291 U.S. 657, to review the affirmance of a recovery from the Railroad in an action for personal injuries suffered in a highway crossing accident. The Supreme Court of Ohio refused to take up the case.