KNOXVILLE, Tenn. - A judge did not err by failing to instruct a jury on the impact of finding a defendant negligent under the Federal Employers' Liability Act (FELA), a Tennessee appeals court held Dec. 27 in remanding a case so a judge could decide whether the evidence supports an $8.6 million asbestos verdict (Anne Payne v. CSX Transportation Inc., No. E2012-02392-COA-R3-CV, Tenn. App.; 2013 Tenn. App. LEXIS 836).