CSX Transp., Inc. v. McBride - 564 U.S. 685, 131 S. Ct. 2630 (2011)

Rule:

Liability under the Federal Employers' Liability Act (FELA), 45 U.S.C.S. § 51 et seq., is limited in these key respects: Railroads are liable only to their employees, and only for injuries sustained in the course of employment. FELA's language on causation, however, is as broad as could be framed. Given the breadth of the phrase "resulting in whole or in part from the railroad's negligence," and Congress' humanitarian and remedial goals, the U.S. Supreme Court has recognized that, in comparison to tort litigation at common law, a relaxed standard of causation applies under FELA. Under FELA, the test of a jury case is simply whether the proofs justify with reason the conclusion that employer negligence played any part, even the slightest, in producing the injury or death for which damages are sought.

Facts:

Respondent McBride, a locomotive engineer with petitioner CSX Transportation, Inc., an interstate railroad, sustained a debilitating hand injury while switching railroad cars. He filed suit under the Federal Employers' Liability Act (FELA), which held railroads liable for employees' injuries resulting in whole or in part from carrier negligence. McBride alleged that CSX negligently required him to use unsafe switching equipment, and failed to train him to operate that equipment. A verdict for McBride would be in order, the District Court instructed, if the jury found that CSX's negligence caused or contributed to his injury. The court declined CSX's request for additional charges requiring McBride to show that CSX’s negligence was a proximate cause of the injury and defining proximate cause as any cause which, in natural or probable sequence, produced the injury complained of. Instead, relying on Rogers v. Missouri Pacific R. Co., 352 U.S. 500, 77 S. Ct. 443, 1 L. Ed. 2d 493, the court gave the Seventh Circuit's pattern FELA instruction: “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 jury returned a verdict for McBride. On appeal, CSX renewed its objection to the failure to instruct on proximate cause. The Court of Appeals affirmed.

Issue:

Before an employer could be held liable under the FELA, should there be a finding that the negligence of the employer was the proximate cause of the employee’s injury?

Answer:

No.

Conclusion:

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. According to the Court, 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. Accordingly, the judgment of the appellate court was affirmed.