Frazier v. Burlington N. Santa Fe Corp.
Annotate this CaseA collision at a railroad crossing between a vehicle and a freight train owned and operated by the BNSF Railway Company resulted in the deaths of all four occupants of the car. The representatives of the decedents' estates brought separate wrongful death claims against BNSF. During trial, the district court instructed the jury, without objection from BNSF, to apply a common-law or "reasonable person" standard of care. The jury returned a verdict in appellants' favor. BNSF moved for a new trial, contending that the trial court erred by not applying the standard of care established by applicable federal regulations. The court of appeals concluded that the jury instruction and special verdict form using a common-law duty of care constituted plain error that substantially affected BNSF's rights and the fairness and integrity of the proceedings and remanded the matter. The Supreme Court reversed, holding that any error in the instructions and verdict form did not affect the fairness and integrity of the proceedings.
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