There's an achievement in Red Dead Redemption for tying a woman to the traintracks, ala old silent films. There isn't one for tying 19 people to the tracks.
That didn't stop this enterprising player from performing the feat, though, finding a spot where train tracks pass close to a busy road then getting busy with the rope.
Interesting that the achievement is triggered and not a wanted level. Guess killing 19 people is OK if you use a little imagination!