Friday, December 6, 2013

Dice v. Akron, Canton & Youngstown Railroad Co. case brief

Dice v. Akron, Canton & Youngstown Railroad Co. case brief summary
342 U.S. 359 (1952)


CASE SYNOPSIS
Petitioner, an injured railroad fireman, sought a writ of certiorari to review the judgment of the Supreme Court of Ohio that held that state law applied to the validity of a release under the Federal Employers Liability Act, 45 U.S.C.S. § 51 et seq., and that reversed the judgment in favor of petitioner.

CASE FACTS
Petitioner, a railroad fireman, was seriously injured when the engine in which he was riding jumped track. Petitioner brought suit under the Federal Employers Liability Act, 45 U.S.C.S. § 51 et seq. Respondent employer alleged that petitioner signed a document releasing respondent in full. Petitioner alleged respondent told him the documents were merely receipts for back wages and denied that he made a full and complete settlement. The jury found in favor of petitioner, but the trial court entered a judgment notwithstanding the verdict. The court of appeals reversed the judgment. The state supreme court reversed the court of appeals. Petitioner sought a writ of certiorari.

DISCUSSION

  • The court granted the petition and reversed, holding that federal law applied to determine the validity of the release. 
  • The release was void because petitioner was induced to sign it by respondent's deliberately false and material statements. 
  • The state supreme court should not have taken away petitioner's verdict because issues of fraud had been submitted to the jury on conflicting evidence, which were determined in petitioner's favor.

CONCLUSION
The court granted the petition for certiorari, and reversed the order reversing the judgment for petitioner. The case was remanded for further action. Federal law applied to the validity of the release, which was void because petitioner was induced to sign it by respondent's deliberately false and material statements.

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