CSX Transportation, Inc. v. Pyramid Stone Industries, Inc.

CSX Transportation, Inc. (CSXT), appeals the district court’s entry of summary judgment in favor of Pyramid Stone Industries, Inc. On appeal, CSXT argues that its negligent hiring, retention, training and supervision claims should have survived summary judgment and that, consequently, summary judgment was not appropriate for its punitive damages claim. For the reasons set forth below, we affirm.

BACKGROUND

On November 24, 2005, a northbound CSXT train derailed at a rural railroad crossing in Elberton, Georgia because of track damage. CSXT had closed the crossing two months earlier. The accident…