International & Great Northern Railroad v. Richmond

In the written argument on motion for rehearing, counsel for appellant makes this statement: "We respectfully submit that the court is not justified, under the facts in this case, in finding that there were accessible to Johnson, the owner of the land adjoining appellant's right of way where the animals went upon the track, and his tenants, other convenient ways open to the public road. According to the testimony of William Creed, the uncle of the young man who had the stock in charge at the time of the alleged injury, the upper crossing, near the upper side of the field, is in bad condition…