Atlantic Coast Line R. Company v. Daniels

Georgia Court of Appeals · 1911 · Torts

70 S.E. 203 (Ga. Ct. App. 1911)

Updated July 23, 2026

TortsNegligenceProximate CauseContributory Negligencefright-induced injuryemergencyjury questionordinary prudence under the circumstances

Facts

The plaintiff approached a Savannah street railroad crossing where raised crossing bars signaled that it was safe to cross, and because the tracks curved, travelers could not tell a train was coming except by observing the bars. After the plaintiff drove onto the tracks with his automobile set at maximum power for the uphill approach, the towerman suddenly lowered the bars on both sides, trapping him on the tracks as a train approached. The plaintiff stopped, pushed the automobile across tracks while the towerman shouted that the train was coming, and after the train passed and the bars were raised, he allegedly remained so unnerved by the fright that he forgot the power settings and tried to crank the automobile, which kicked back and injured his face and mouth. The defendant argued on demurrer that its negligence was not the proximate cause and that the plaintiff's own cranking of the automobile caused the injury.

Issue

When a defendant's negligence creates a frightening emergency, and the plaintiff is later injured by acting in a confused or frightened state, can the defendant's negligence be treated as the proximate cause of the injury? More specifically, does the petition state a claim where the plaintiff alleges that fright caused by being trapped on railroad tracks made him forget the dangerous setting of his automobile before cranking it?

Rule

In determining proximate cause, the plaintiff's own conduct is judged by comparing it to that of an ordinarily prudent person under the same circumstances, including circumstances of fright not within the plaintiff's control. If the defendant's negligence creates a situation that would naturally frighten a normal person to such a degree as to impair memory or judgment, and the plaintiff's resulting act and injury follow from that fright, the defendant's negligence may be treated as the sole, direct, and proximate cause; whether the fright was normal and whether the plaintiff's conduct met that standard are questions for the jury when reasonable minds could differ.

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In Macon, Jordan Pike entered a parking garage after the attendant at Peach Lantern Garage waved him forward. As Jordan drove onto a steep exit ramp, the attendant mistakenly dropped a steel barrier behind him and yelled that a delivery truck was rolling backward toward the ramp. Jordan scrambled out, shoved his stalled car to the side, and moments later, still badly shaken, forgot that he had left the transmission engaged; when he tried to restart the car, it lurched and crushed his foot.

If Jordan sues Peach Lantern Garage for negligence and the garage argues Jordan's own restart attempt was the sole proximate cause, what is the best answer?

Explanation. The governing rule is that if a defendant's negligence creates a frightening situation that would naturally cause a normal person to lose memory or judgment, the defendant's negligence may be treated as the proximate cause of a later injury resulting from the plaintiff's frightened conduct. The plaintiff's conduct is judged by what an ordinarily prudent person would do under the same frightened circumstances. Here, Jordan's restart attempt is not automatically a superseding cause, and the case would ordinarily go to the jury because reasonable minds could differ on whether the fright was normal and whether his conduct was prudent under that fright. (Derived from Atlantic Coast Line R. Company v. Daniels (1911).)