Seaboard Air Line Railway v. Callan

In an action for personal injuries Callan alleges in the first count of his declaration that while he was in a wagon crossing a street called Manatee Avenue in the City of Manatee, Florida, “the defendant by its servants and employees wrongfully, carelessly and negligently caused the cars of one of its trains to be propelled backward without any warning across said Avenue at and on said crossing and towards and upon the said wagon of plaintiff, and thus wrongfully, carelessly and negligently caused the rear car of its said train to collide with said wagon in which plaintiff was then and there…