Dice v. Akron, Canton & Youngstown Railroad Co.

Brief Fact Summary.

Petitioner sued Respondent in state court, under federal law, for negligence. Respondent argued Petitioner had signed a release of all claims.

Synopsis of Rule of Law.

Federal questions arising in state court are governed by federal law

Facts.

Dice (Petitioner) was injured on the railroad track owned by Akron, Canton & Youngstown Railroad Co. (Respondent) when working as a railroad fireman. Petitioner brought suit against Respondent for negligence under the Federal Employers’ Liability Act in an Ohio state court. Respondent argued that Petitioner had signed a release of all claims. Petitioner argued that he thought he had signed a receipt for back pay.

Issue.

Is the validity of a release under the Federal Employers’ Liability Act governed by state law?

Held.

No, federal law governs the validity of a release under the Federal Employers’ Liability Act. The decision of the Ohio Supreme Court is reversed and remanded.

Concurrence.

Justice Frankfurter

Justice Frankfurter agreed that the validity of the release should be governed by federal law, but argued that the issue should be determined by the judge rather than jury because the Court must respect Ohio’s policy requiring all issues of fraud to be determined by a judge.

Discussion.

The Court agreed with the Ohio Court of Appeals that federal law governed the case, because the validity of the release under the Federal Employers’ Liability Act was a federal question to be interpreted by the jury. The Court further agreed that the release was void under the Federal Employers’ Liability Act because the jury had found ample evidence that Petitioner was induced to sign the release by false and material statements.