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.
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. The court granted the petition and reversed, holding that federal law applied to determine the validity of the release.
Did the validity of releases under the Federal Employers' Liability Act raises a federal question to be determined by federal rather than state law?
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. 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. Manifestly the federal rights affording relief to injured railroad employees under a federally declared standard could be defeated if states were permitted to have the final say as to what defenses could and could not be properly interposed to suits under the Act. Moreover, only if federal law controls can the federal Act be given that uniform application throughout the country essential to effectuate its purposes.