Bayne v. Todd Shipyards Corp.

Case brief summary

Facts

A truck driver delivering goods to a shipyard fell off a loading platform that lacked a required safety railing, and he sued the shipyard for his injuries.

Procedural history

The trial judge told the jury the missing railing was only evidence of carelessness, not automatic proof, the jury ruled for the shipyard, and an appeals court upheld that result in an unpublished ruling.

Issue

Does breaking a safety rule issued by a state labor agency automatically count as negligence, or is it merely one piece of evidence a jury may consider?

Holding

The Supreme Court held that violating this type of official safety regulation is negligence per se, meaning it automatically counts as careless conduct.

Reasoning

This safety rule went through official public review before being adopted, so it carries real legal force. It protects any worker legally on site, not just shipyard employees.

Opinions

Majority (Brachtenbach): Violating a government safety regulation adopted through formal public rulemaking is automatic proof of negligence, and the case must be retried with that correct legal standard.