37 La. Ann. 694, 698 (1885)
Mr. Reynolds and his wife, together with their sister-in-law, three small children, and two colored attendants, purchased tickets as passengers on the defendant railway and arrived at the depot at Morrogh Station to board the east-bound train, which was due around midnight but did not arrive until about two o'clock in the morning.1 The group was at the depot for the purpose of boarding the train.2
The passage from the depot to the passenger cars involved descending a stairway of several steps.3 These steps ran parallel to the track and led to a lower platform five feet wide.4 After reaching the platform, passengers turned right to pass between uncoupled freight cars.5 A ditch lay to the left of the steps, and a slope ran from the platform to the bottom of another ditch.6 If a passenger went too far to the left or forward, he would fall into the ditch or down the slope.7
No stationary lights were provided at the depot or steps.8 There was no moon that night.9 The lights from the engine and passenger coaches were blocked by the freight cars, and the station room lights did not reach the bottom of the steps, leaving the area insufficiently illuminated despite possible lanterns carried by employees.10 The absence of sufficient light rendered the passage insecure for passengers unfamiliar with it.11
Passengers were warned to hurry up because the train was behind schedule.12 Mrs. Reynolds, a corpulent woman weighing two hundred and fifty pounds who had just left the bright light of the sitting room, made a misstep while descending the unlighted steps and fell beyond the platform down the slope, sustaining a dislocation of the ankle and a fracture of the leg below the knee.13
Mr. Reynolds's absence from his wife resulted from the station agent's direction that he assist in loading baggage due to absent employees.14 After the accident, Mrs. Reynolds continued the journey to Florida without seeking medical attention until arrival.15 The district court awarded her two thousand dollars in damages, which the Supreme Court of Louisiana reviewed on appeal from the defendant's challenge.16
Whether the defendant railway company was negligent in failing to provide sufficient lighting for passengers boarding the train at night?17
The duty of railway carriers to provide safe modes of egress and ingress to and from their cars, and to provide sufficient lights at their stations where passengers take or leave their trains at night, is well established by authority.18
Yes. The established facts show that no stationary lights were provided for the depot platform or the steps.19 There was no moon on the night in question.20 The lights of the engine and passenger coaches were intercepted by the intervening freight cars, and the lights in the rooms of the station could have shed no light on the bottom of the steps.21
These conditions left the passage insecure for passengers unfamiliar with it, as the steps were unprotected by railing with a ditch to the left and a slope beyond the narrow platform.22 The absence of sufficient light constituted negligence on the part of the company in failing to perform its duty of providing safe modes of ingress and egress between its depots and its trains.23
The defendant railway company was negligent in failing to provide sufficient lighting for passengers boarding the train at night.24
Whether the company's failure to provide sufficient lighting caused Mrs. Reynolds's fall and injuries?25
Where the negligence of the defendant greatly multiplies the chances of accident to the plaintiff, and is of a character naturally leading to its occurrence, the mere possibility that it might have happened without the negligence is not sufficient to break the chain of cause and effect between the negligence and the injury.26
Yes. Mrs. Reynolds, a corpulent woman weighing two hundred and fifty pounds, emerging from the bright light of the sitting-room which naturally exaggerated the outside darkness, hastened down these unlighted steps.27 She made a misstep in some way and was precipitated beyond the narrow platform in front and down the slope beyond.28 The whole tendency of the evidence connects the accident with the negligence.29
The lack of light exposed passengers to danger of fall and injury at night while the negligence greatly multiplied the chances of such an occurrence.30
The company's failure to provide sufficient lighting caused Mrs. Reynolds's fall and injuries.31
Whether Mr. Reynolds was contributorily negligent in not accompanying his wife?32
Contributory negligence on the part of the husband in leaving his wife to grope her way unattended by himself would require examination.33 If his absence was due to another fault of the defendant's station agent it does not constitute contributory negligence.34 A corpulent but not infirm woman is fully capable of taking care of herself.35
No. The evidence satisfies that Reynolds’ absence was due to another fault of defendant’s station agent in requiring him to assist in putting his own baggage on the cars, because some of the employees whose duty it was were absent.36 Aside from this, his wife, though corpulent, was not an infirm woman and was fully capable of taking care of herself.37 Therefore there is no contributory negligence on the part of the husband.38
Mr. Reynolds was not contributorily negligent in not accompanying his wife.39
Whether the district court's award of two thousand dollars in damages was proper?40
The quantum of damages is determined based on the injury suffered, including dislocation of the ankle and fracture of the leg below the knee with no loss of the limb.41 The court considers the suffering and any unusually imprudent conduct that may have increased and prolonged the effects of the injury.42
Yes. The injury consisted in a dislocation of the ankle and a fracture of the leg below the knee with no loss of the limb.43 Notwithstanding the accident she went on the cars and continued without interruption her long railroad journey to Florida without availing herself of medical attention.44 Even after arrival there she received but trifling medical aid.45
These facts impressed the district judge as they do the reviewing court.46 Although no doubt she suffered greatly, the district judge allowed her two thousand dollars as damages which will not be disturbed.47
The district court's award of two thousand dollars in damages was proper.48