Railroad companies may be held liable in some instances for scaring horses.

Title 58 – Public Utilities, Services and Carriers
CHAPTER 17.
THE GENERAL RAILROAD LAW
ARTICLE 27.
SAFETY; NOTICE OF ACCIDENTS

SECTION 58-17-3360. Electric hand lanterns shall be used in switching and moving trains.

All railroad carriers shall equip trainmen in their employ engaged in switching and train movements in intrastate commerce in this State with electric hand lanterns, of a type approved by the Public Service Commission, containing at least one extra bulb capable of being immediately lighted in case of failure of the main bulb. The use by any railroad carrier of oil lanterns in connection with such movements is hereby prohibited. Any railroad carrier violating any of the provisions of this section shall be punished by a fine not less than twenty-five dollars nor more than one hundred dollars and each day during which any flagrant violation shall continue shall constitute a separate offense.

SECTION 58-17-3400. Removal of hand or lever cars from track and leaving it near crossing shall be unlawful.

It shall be unlawful for any railroad section master or any person in charge of or connected with any hand car or lever car to remove it from any railroad track and continue it stationary within fifty yards of any public crossing other than at any regular railroad section house except when necessary to avoid an approaching train or when in charge of employees engaged in actual work upon such crossing, and then only for such a period as is necessary to avoid such train or to perform such work. Any person violating the provisions of this section shall, upon conviction, be fined not exceeding fifty dollars or be imprisoned not exceeding thirty days. Any railroad company shall be liable for damages for any horse frightened as a result of the violation of the provisions of this section by any of its employees.