Law School Case Brief
Moore v. Chesapeake & O. R. Co. - 291 U.S. 205, 54 S. Ct. 402 (1934)
The Safety Appliance Act prescribes duties, and injured employees are entitled to recover for injuries sustained through the breach of the duties. Questions arising in actions in state courts to recover for injuries sustained by employees in intrastate commerce and relating to the scope or construction of the Safety Appliance Act are federal questions that may appropriately be reviewed in the Supreme Court of the United States. But it does not follow that a suit brought under a state statute that defines liability to employees who are injured while engaged in intrastate commerce, and brings within the purview of the statute a breach of the duty imposed by the federal statute, should be regarded as a suit arising under the laws of the United States and cognizable in federal court in the absence of diversity of citizenship. The Safety Appliance Act, while prescribing absolute duties, and thus creating correlative rights in favor of injured employees, does not attempt to lay down rules governing actions for enforcing such rights.
Petitioner Moore was employed as a switchman by respondent Chesapeake & O. R. Company ("Chesapeake"); he was injured while attempting to uncouple freight cars. Moore subsequently filed a lawsuit against Chesapeake in federal district court to recover damages for his injuries. Moore alleged causes of action under the Federal Employers' Liability Act and the Safety Appliance Act. A general verdict in favor of Moore was rendered, and the district court entered judgment on the verdict. Chesapeake appealed, and the court of appeals reversed the judgment on the ground that the district court was without jurisdiction to entertain the case. Moore was granted a writ of certiorari.
Did the district properly exercise jurisdiction over Moore's action?
The Supreme Court of the United States Court reversed the appellate court's judgment and remanded the case to that court with directions to consider the other questions presented by Chesapeake appeal from the judgment in favor of Moore. The Court ruled that the allegations set forth in the first paragraph of the Moore's complaint set forth a cause of action under the Federal Employers' Liability Act. Every essential ingredient of such a cause of action was appropriately alleged. The Court further held that in view of the diversity of citizenship between the parties and the residence of Moore, the district court had jurisdiction over the action.
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