U.S. Supreme Court Reaffirms "Any Part" Causation Standard in FELA Cases
On June 23, 2011, the U.S. Supreme Court affirmed the Seventh Circuit Court of Appeals decision in CSX Transp., Inc. v. McBride, holding that it is sufficient for a plaintiff in a Federal Employers' Liability Act (FELA) case to prove that the negligence of their employer was a contributing legal cause of the injury. FELA holds railroads liable for their employee's injuries resulting in whole or in part from carrier negligence. The U.S. Supreme Court held that under FELA it is not necessary to prove that the employers' negligence was the proximate cause of the injury. The injured party simply has to show that the employer's negligence played any part in producing the injury.
McBride worked as a locomotive engineer for CSX Transportation, Inc. (CSX). McBride brought this action after he injured his hand while switching railroad cars. McBride commenced a FELA case alleging that CSX was negligent in requiring him to use unsafe equipment and failing to properly train him to operate the equipment. FELA renders railroads liable for employee's injuries or deaths resulting in whole or in part from the carriers' negligence. The District Court instructed the jury using the Seventh Circuit's pattern instruction for FELA cases, stating that a verdict in favor of McBride would be in order if the jury found that CSX's negligence played a part, no matter how small, in causing or contributing to his injury. The Court declined CSX's request that the jury be advised on the issue of proximate cause. The jury returned a verdict in favor of McBride. CSX appealed to the Seventh Circuit, arguing that the District Court failed to properly instruct the jury on the issue of proximate cause. The Seventh Circuit approved the District Court's instructions and affirmed the judgment entered on the jury's verdict.
The U.S. Supreme Court held that FELA does not incorporate proximate cause standards developed in non-statutory common-law tort actions. The U.S. Supreme Court relied on its earlier decision in Rogers v. Missouri Pacific R. Co. 352 U.S. 500, and reaffirmed that the test for causation in a FELA case is whether the employer's negligence played any part, even the slightest, in producing the injury for which damages are sought. Further, the U.S. Supreme Court stated that the Rogers test has been accepted as settled law for several decades with countless judges instructing juries using language taken from Rogers on this same issue. To upset this area of well settled law would not serve the Courts goals of stability and predictability that the doctrine of stare decisis aims to ensure.
Accordingly, the U.S. Supreme Court affirmed the decision of the Seventh Circuit and held that an employee need only show that the defendants' negligence played any part in producing the injury.
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