Dice v. Akron, Canton & Youngstown R. Co

Brief Fact Summary. Plaintiff, a railroad employee, sued Defendant, a railroad, in Ohio state court under the Federal Employers’ Liability Act (FELA) for injuries sustained on the railroad. Defendant raised the defense that Plaintiff had signed a release, which Plaintiff alleged was misrepresented to Plaintiff by Defendant as a release from back wages. There was a jury verdict for Plaintiff, which the judge reversed, finding that under Ohio law, the release was binding on Plaintiff.

Synopsis of Rule of Law. In cases brought under the Federal Employers’ Liability Act (FELA), issues pertaining to the employee’s ability to enforce his/her federal right is determined by federal law. Fact issues to be decided under FELA are determined by a jury in order to comply with FELA and the Seventh Amendment to the U.S. Constitution.

Facts. Plaintiff Dice, a railroad employee, sued Defendant Akron, Canton & Youngstown R. Co. in Ohio state court under FELA for injuries sustained on the job. Defendant asserted that Plaintiff had signed a release. Plaintiff argued that Defendant told Plaintiff that the “release” was a receipt for back wages and Plaintiff never consented to release Defendant of liability. This issue as well as the issues of liability was presented to the jury. The jury returned a verdict for Plaintiff. The trial judge reversed the judgment notwithstanding the verdict on the grounds that Plaintiff could read and was of reasonable intelligence so that he could not argue that the release was not binding. The intermediate appellate court reversed, stating federal law applied and that the judge could not reverse the jury’s verdict because there was enough evidence of Defendant’s fraud. The Supreme Court of Ohio reversed the intermediate appellate court, stating that Ohio law applied and that under Ohio law, a person of reasonable intelligence that can read must be bound by the signed release notwithstanding Defendant’s false statements and that facts pertaining to fraud are decided by the judge and not the jury. Plaintiff appealed to the Supreme Court of the United States.

Issue. Does state law apply to the validity of releases under FELA?

Held. No. Reversed and remanded. The federal right given an individual under FELA and the parameters of such must be determined by federal law. Under federal law, a release is not valid if procured by the false and misleading statements of Defendant’s representatives. Applying Ohio law and consequently making the release valid if Plaintiff was negligent in not reading it would defeat the purpose of FELA of giving employees a right to recover against their employers. In addition, there is a federal policy of not allowing individuals to escape liability through fraudulently obtained releases. Plaintiff has a right under FELA and the Seventh Amendment to a trial by jury. This cannot be taken away by Ohio’s law giving the judge permission to decide the issue of fraud in the context of a release. Concurrence. Justice Frankfurter found that the majority’s decision that the validity of the release is determined by federal law to be correct. However, the requirement by the Court that state courts in FELA cases have juries determine issues of fraud is contrary to the policy of allowing states to govern their own court systems. There is no case nor statute requiring that states give jury trials for FELA cases so long as the state court does not have jury trials for negligence cases. The majority opinion requires Ohio to treat its FELA cases differently than other negligence cases. This is undue interference with the state court system and because it is not required by any precedent or statute, it should not be imposed on the state courts.

Discussion. The majority illustrates the supremacy of federal law in state court action when the action is brought pursuant to a federal right, such as under FELA. In order to reach its decision, the Court had to determine that the Ohio rule permitting state court judges to determine if fraud had occurred was a substantive rule affecting the claim of the Plaintiff based on federal law. Because the effect of the application of the state court rule regarding judicial finding of fraud is to, in its application to the facts presented here, preclude the Plaintiff’s federal law claim, the state court rule may not be appli