Grimstad v. New York Central Railroad Co.

264 F. 334 (1920)

Quick Summary

Elfrieda Grimstad (plaintiff) sued New York Central Railroad Co. (defendant) after her husband, Angell Grimstad, drowned because their barge lacked life preservers. The dispute centered on whether this lack of safety equipment constituted negligence under the federal Employers’ Liability Act.

A jury found New York Central negligent; however, upon appeal, it was determined that there was no evidence to prove that life preservers would have saved Grimstad’s life, leading to a reversal of the initial verdict.

Facts of the Case

Elfrieda Grimstad (plaintiff), the widow of Angell Grimstad, filed a lawsuit against her late husband’s employer, New York Central Railroad Co. (defendant). Angell Grimstad was the captain of the Grayton, a barge owned by New York Central. The incident leading to this legal dispute occurred when the Grayton was docking in Erie Basin, Brooklyn, and a tugboat collision resulted in Captain Grimstad falling into the water.

Grimstad, who could not swim, drowned despite his wife’s attempt to save him with a rope; she discovered there were no life preservers on board which might have aided in his rescue.

The plaintiff argued that New York Central Railroad Co. was negligent for not equipping the barge with life preservers or other flotation devices that could have potentially saved her husband’s life. Following the tragedy, Grimstad’s wife sought damages under the federal Employers’ Liability Act, claiming that the absence of such safety equipment constituted negligence on the part of the defendant.

Procedural Posture and History

  1. A lawsuit was filed by Elfrieda Grimstad against New York Central Railroad Co. alleging negligence.
  2. The trial court denied the defendant’s motion to dismiss and ruled in favor of the plaintiff.
  3. New York Central Railroad Co. appealed the decision.

I.R.A.C. Format


Whether New York Central Railroad Co. was negligent in failing to provide life preservers or other safety equipment on the barge, which might have prevented Angell Grimstad’s drowning.

Rule of Law

The employer has a duty to furnish its employees with a reasonably safe place to work and proper equipment, which includes necessary and proper appliances for safety.

Reasoning and Analysis

The appellate court focused on whether the lack of life-preserving equipment on the barge directly contributed to Angell Grimstad’s death. They assessed whether life buoys or other flotation devices would have realistically been able to save him. The court determined that there was no evidence to support the idea that such equipment would have made a difference in the outcome.

It was highlighted that the immediate cause of death was falling into the water and that there was no clear indication that having a life buoy readily available would have led to a successful rescue.

Furthermore, the court reasoned that it was purely speculative to assume that Grimstad’s wife could have retrieved and effectively used a life buoy in time to save her husband. Without concrete evidence, it was concluded that the jury had engaged in conjecture when determining the defendant’s negligence based on the absence of life-saving equipment.


The judgment of the trial court was reversed due to insufficient evidence showing that the provision of life-saving equipment would have prevented Angell Grimstad’s death.

Key Takeaways

  1. An employer must provide necessary safety equipment to employees, but liability for negligence depends on whether such equipment could have realistically prevented injury or death.
  2. Judicial outcomes may be reversed if a jury’s finding is based on speculation rather than concrete evidence.
  3. The proximate cause of injury or death is critical in determining negligence and liability in workplace accidents.

Relevant FAQs of this case

What determines whether an employer has breached their duty to provide a safe working environment?

The determination hinges on whether the employer has failed to take reasonable steps to prevent foreseeable harm, considering industry standards, past incidents, and the nature of the employment. Employers must assess potential hazards and implement measures to mitigate them.

  • For example: In a factory setting, if machinery is known to cause injuries without proper guarding, it would be a breach of duty if the employer does not install safety guards.

How does the concept of proximate cause relate to negligence claims in the workplace?

Proximate cause refers to whether there is a direct link between an employer’s negligence and the employee’s injury or death. A claim may not stand if the injury could not have been foreseen or prevented by the employer’s actions.

  • For example: If a warehouse employee is injured by falling products that were improperly stacked despite safety training, proximate cause may be established as the lack of care in stacking led directly to the injury.

In what ways can the absence of safety equipment lead to employer liability?

An employer can be held liable if it can be proven that the absence of safety equipment was a substantial factor in causing harm and that providing such equipment would have been a standard practice for safety.

  • For example: A construction company could be held liable for an employee’s fall if they failed to provide harnesses typically used for work at heights.
Last updated

Was this case brief helpful?

More Case Briefs in Torts