Wednesday, January 1, 2014

CSX Transportation, Inc. v. McBride case brief

CSX Transportation, Inc. v. McBride case brief summary
131 S.Ct. 2630 (2011)

CASE SYNOPSIS
Petitioner, a railroad employer, sought review of a decision of the United States Court of Appeals for the Seventh Circuit, which affirmed a district court decision awarding respondent, a railroad employee, damages in his negligence action under the Federal Employers' Liability Act (FELA), 45 U.S.C.S. § 51 et seq. A writ of certiorari was granted.

CASE FACTS
The employee worked as a locomotive engineer for the employer. The employee injured his hand using an independent brake to switch rail cars.

PROCEDURAL HISTORY
The district court rejected the employer's requested instruction that would have required the employee to show that the employer's negligence was a proximate cause of the injury. Instead, the district court employed the Seventh Circuit's pattern instruction for FELA cases, which read: "Defendant 'caused or contributed to' Plaintiff's injury if Defendant's negligence played a part--no matter how small--in bringing about the injury. The mere fact that an injury occurred does not necessarily mean that the injury was caused by negligence." The jury returned a verdict for the employee. The Court of Appeals affirmed.

DISCUSSION

  • The Supreme Court held that, pursuant to 45 U.S.C.S. § 51, FELA rendered railroads liable for employees' injuries or deaths resulting in whole or in part from carrier negligence. 
  • FELA did not incorporate proximate cause standards developed in nonstatutory common-law tort actions. 
  • Under FELA, injury was proximately caused by the railroad's negligence if that negligence played any part in causing the injury.

CONCLUSION
The Court affirmed the decision of the Court of Appeals. 5-4 decision; 1 opinion; 1 dissent; 1 Justice joined all but Part III-A of the majority opinion.

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