Law School Case Brief
Dice v. Akron, C. & Y. R. Co. - 342 U.S. 359, 72 S. Ct. 312 (1952)
Validity of releases under the Federal Employers' Liability Act, 45 U.S.C.S. § 51 et seq., raises a federal question to be determined by federal rather than state law.
Dice, a railroad fireman, was seriously injured when the engine in which he was riding jumped the tracks. Dice brought a negligence suit under the Federal Employers Liability Act. His employer, Akron, Canton & Youngstown Railroad Co. (“Akron”), alleged that Dice had signed a document releasing Akron in full. Dice alleged Akron 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 Dice, but the trial court entered a judgment notwithstanding the verdict, holding the Ohio state law imposed a duty on Dice to read the document before signing it. However, the state court of appeals reversed holding that federal law would have allowed evidence of the railroad's fraud, which would preclude enforcement of the release . The state supreme court reversed the court of appeals holding that state law applied to the validity of a release. Dice sought a writ of certiorari asserting that federal law should be applied.
Should federal law be applied in determining the validity of the release?
The Court granted the petition and reversed, holding that federal law applied to determine the validity of the release because Dice had brought the case under the FELA, a federal statute. The release was void because Dice had been induced to sign it by the railroads deliberately false and material statements made in securing the release. The state supreme court should not have taken away Dice's verdict because the issues of fraud that had been submitted to the jury on conflicting evidence were determined in Dice’s favor.
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