In Richards v. Consol. Rail Corp., 330 F.3d 428, 431, 437 (6th Cir. 2003), a train stopped suddenly because of an apparent malfunctioning of the brake system in a car.
Plaintiff, the conductor, was responsible for inspecting each car's brake system in these situations, a process that required him to crouch down and examine the underside of each car. While so doing, he slipped and injured his back. Id. at 431.
The District Court granted the railroad's motion for summary judgment because "the subsequent slip and injury bears too tenuous a connection" to the brake failure. Id.
The Circuit Court of Appeals reversed, finding that "courts . . . should focus on whether a reasonable jury could conclude that the railroad's negligence played any part, even the slightest, in bring about the plaintiff's injury." Id. at 437.