Angell Grimstad was the captain of the Grayton, a barge that was owned by New York Central Railroad (New York Central) (defendant). The barge was docked at the piers in Erie Basin, Brooklyn. As it was docking, a tugboat bumped against the Grayton, causing Grimstad to fall overboard. Grimstad did not know how to swim. Grimstad’s wife (plaintiff) discovered Grimstad flailing in the water. Grimstad’s wife ran into the barge’s cabin to retrieve a rope, but by the time she returned with the rope, Grimstad had drowned. Grimstad’s wife sued New York Central for negligently failing to equip the Grayton with life preservers. New York Central moved to dismiss the suit. The trial court denied New York Central’s motion. A jury found that New York Central had acted negligently by not equipping the Grayton with life preservers. New York Central appealed.