On October 8, 1998, the Seventh Circuit of the United States Court of Appeals affirmed the district court's holding that plaintiff, Charles Reid, was not a permissive user of the railway tracks owned by the defendant, Norfolk & Western Railway Company (N & W).

On September 8, 1998, the second district of the Illinois Appellate Court affirmed the trial court's imposition of sanctions, under Supreme Court Rule 137 (155 Ill 2d R 137), against the appellant, the law firm of Parrillo, Weiss & O'Halloran, for filing a frivolous complaint.