Torts Case Brief 10:31.docx - Torts 10\/31 CSXTransportation,Inc.v McBride United States Supreme Court 131 S.Ct 2630(2011 RuleofLaw The Federal Employers

Torts Case Brief 10:31.docx - Torts 10/31...

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Torts 10/31 CSX Transportation, Inc. v.  McBride United States Supreme Court 131 S.Ct. 2630 (2011) Rule of Law The Federal Employers Liability Act imposes liability upon railroad carriers for injuries sustained by an employee, in the course of his employment, when the carrier’s negligence played any part, even the slightest, in producing the injury. Facts Robert McBride (defendant) worked as a locomotive engineer for CSX Transportation, Inc. (CSX) (defendant), a company that operated an interstate system of railroads. After seriously injuring his hand while operating a train, McBride underwent two surgeries and extensive physical therapy, yet he never regained full use of the hand. McBride commenced a Federal Employers Liability Act (FELA) negligence action against CSX in U.S. District Court alleging that the equipment he operated was unsafe and that CSX had failed to properly train him to operate the equipment. One of the jury instructions requested by CSX would have required McBride to show that CSX’s negligence was a proximate cause of his injury. Another instruction would have defined “proximate cause” to mean “any cause which, in natural or probable sequence, produced the injury complained of.” The district court refused to give the requested instructions. A jury found
for McBride and CSX appealed. The court of appeals affirmed the jury’s verdict and the U.S. Supreme Court granted certiorari to review. Issue Does the Federal Employers Liability Act impose liability upon railroad carriers for injuries sustained by an employee, in the course of his employment, when the carrier’s negligence played any part, even the slightest, in producing the injury? Holding and Reasoning (Ginsburg, J.) Yes. The Federal Employers Liability Act (FELA) renders railroads liable for employees’ injuries or deaths “resulting in whole or in part from [carrier] negligence.” 45 U.S.C. § 51, et seq. The Act does not incorporate “proximate cause” standards commonly developed in non-statutory, common-law tort suits. In Rogers v. Missouri Pacific R. Co. , 352 U.S. 500 (1957), the Court held that the causation language used in FELA is intentionally broad and imposes liability upon carriers for injuries sustained by employees in the course of their employment. In Rogers , the Court noted, “[U]nder [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 .” Id. at 506. Here, the district court properly instructed the jury in accordance with the Court’s decision in Rogers . Nevertheless, CSX argues that proximate causation is a concept fundamental to actions sounding in negligence. While proximate causation is essential to negligence actions, Congress chose not to incorporate proximate cause when enacting FELA. If negligence is proved and is shown to have played any part, even the slightest in producing the injury to a carrier employee, then the carrier is answerable in

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