Amtrak
ST. LOUIS — The U.S. Court of Appeals for the Eighth Circuit reversed a jury verdict and directed the district court to enter judgment for National Railroad Passenger Corporation, which is doing business as Amtrak, in a wrongful death and negligence lawsuit arising from a fatal shooting aboard an Amtrak train in January 2022.
The panel, in an opinion authored by Circuit Judge Leonard Grasz, concluded that the plaintiffs failed to present legally sufficient evidence to support any negligence theory submitted to the jury and that Amtrak was entitled to judgment as a matter of law, according to the court document filed Dec. 31.
The case arose after an unprovoked shooting aboard an Amtrak River Runner train in Missouri.
On Jan. 14, 2022, Marquise L. Webb and Richie Terrell Aaron Jr. separately boarded Amtrak service in Normal, Ill.
Neither individual knew the other, and both later transferred to the River Runner, which operates between St. Louis and Kansas City.
Amtrak prohibits firearms onboard but does not conduct routine passenger security screenings; Webb boarded with a concealed firearm unbeknownst to Amtrak personnel, the document states.
At approximately 9:03 p.m., while the train was stopped at Lee’s Summit, Mo., Webb shot Aaron five times in the back without an apparent motive and then exited the train.
Passengers heard the gunshots, with some initially mistaking the sounds for fireworks, and at least one passenger notified a member of the train crew, but that crewmember apparently dismissed the noises as fireworks.
The train departed at 9:08 p.m., and Amtrak personnel discovered Aaron had been shot before the next station stop at Independence, Mo.
A conductor administered CPR until emergency responders arrived, but Aaron showed no signs of life and was pronounced dead at 9:33 p.m.
Aaron’s widow, Breayonna Aaron, on behalf of herself, Aaron’s estate and their three minor children, filed a lawsuit in March 2022 in the U.S. District Court for the Western District of Missouri against Amtrak and Webb.
The complaint alleged negligence and vicarious liability, negligent hiring, training and supervision and wrongful death under Missouri law.
A default judgment was entered against Webb because he failed to appear or defend in the case; Webb later pled guilty to voluntary manslaughter and related charges and was sentenced to prison.
Amtrak moved for judgment as a matter of law at the close of the plaintiffs’ case, but the district court did not rule on that motion and instead submitted the case to the jury, also allowing punitive damages instruction over Amtrak’s objection.
The jury returned a general verdict finding Amtrak liable and awarded $8.8 million in compensatory damages and $150 million in punitive damages.
The district court subsequently found the punitive damages award constitutionally excessive under the Due Process Clause and reduced it to $35.2 million before entering final judgment.
Amtrak then appealed the denial of its motion for judgment as a matter of law and sought a new trial. The Aarons cross-appealed the punitive damage reduction.
The Eighth Circuit held that plaintiffs failed to establish essential elements of their negligence theories under Missouri law. The appellate panel found there was insufficient evidence to show Amtrak owed a legal duty to protect Aaron from unforeseeable criminal acts of third parties.
The court noted that under Missouri law, a duty arises only when a defendant knew or should have anticipated harm; here, the plaintiffs did not present evidence of prior violent crime on the River Runner that would put Amtrak on notice of such risk.
The court also determined there was insufficient evidence that Amtrak’s actions or inactions caused Aaron’s death.
Expert testimony indicated that even with immediate action by Amtrak employees, Aaron’s chance of survival would have been low, and the plaintiffs failed to show by reasonable medical certainty that Amtrak’s conduct was a but-for cause of death.
In concluding that plaintiffs presented no legally sufficient evidence supporting any negligence theory, the appeals court reversed the district court’s denial of judgment as a matter of law and directed the lower court to enter judgment for Amtrak.
U.S. Court of Appeals for the Eighth Circuit case number: 24-2654
