Training programs face liabilities other than those arising from medical malpractice, such as disciplinary actions, employer-employee disputes, sexual harassment, etc. The incidence of auto accidents in overfatigued medical trainees falling asleep at the wheel is very high, in some surveys close to 50%, and accidents are more likely to occur in the immediate postcall period. Court decisions in analogous factual circumstances, though not involving medical trainees, have favored the accident victim. In one case, the court noted that “… the appellee (Norfolk & Western Railway Company, the employer) could have reasonably foreseen that its exhausted employee, who had been required to work 27 hours without rest, would pose a risk of harm to other motorists …” In another case, the court held that “the defendant corporation (McDonald's Restaurants of Oregon Inc.) knew or should have known that its employee was a hazard to himself and others when he drove home from the workplace after working numerous hours.”