Baltimore & Ohio Railroad Co. v. Goodman — Quick Summary

Baltimore & Ohio Railroad Co. v. Goodman

275 U.S. 66 (1927) (U.S. Supreme Court)

In Brief

Baltimore & Ohio Railroad Co. v.

Key Issue

When a motorist approaches a railroad grade crossing with an obstructed view, is the motorist's failure to stop and, if necessary, get out of the vehicle to look for approaching trains contributory negligence as a matter of law that bars recovery?

The Rule

When the standard of conduct for safety is clear, courts should declare it as a matter of law rather than submit the question to a jury. A traveler approaching a known railroad crossing must use ordinary care to avoid a collision—at a minimum, to stop, look, and listen—and, if a clear view cannot otherwise be obtained, to get out of the vehicle and look from a vantage point that permits adequate observation. Reliance on the railroad's signals or the absence of warnings does not excuse the traveler's failure to take these precautions. Failure to do so constitutes contributory negligence as a matter of law.

Bottom Line

Yes. Goodman was contributorily negligent as a matter of law for crossing without stopping and, given his obstructed view, for failing to get out to look; the railroad was entitled to judgment, and the plaintiff's recovery was barred.

Why It Matters

Goodman is central to three negligence themes. First, it exemplifies contributory negligence as a complete bar to recovery, underscoring the high stakes of a plaintiff's own care. Second, it demonstrates judicial willingness to convert a jury question into a rule of law when the court views the duty as clear and administrable. Third, it sparked an important corrective in Pokora v. Wabash Ry. (1934), where the Court, per Justice Cardozo, warned against rigid formulas like the "get out and look" mandate and restored a greater role for the jury in fact-laden negligence assessments. For law students, Goodman frames the dialectic between bright-line duty rules and flexible, jury-driven reasonableness standards—and illustrates how evolving policy judgments (including the shift to comparative negligence in many jurisdictions) can shape the law's treatment of plaintiff conduct.

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