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Dice v. Akron, Canton & Youngstown R. Co

    Brief Fact Summary. Dice (Petitioner), a railroad fireman, was seriously injured when
    an engine in which he was riding left the track. Alleging that his injuries were due to Akron, Canton, & Youngstown R. Co.’s (Respondent) negligence, he brought an action for damages under the Federal Employers’ Liability Act (Act) in the Court of Common
    Pleas of Ohio.

    Synopsis of Rule of Law. The right to trial by jury is a basic and fundamental feature of our system of federal jurisprudence and it is part and parcel of the remedy offered to railroad workers under the Act.


    Facts. Respondent offered several affirmative defenses, including a written document
    signed by Petitioner purporting to release Respondent from all liability in full for $924.63. Petitioner admitted that he had signed several receipts for payment made to him, but denied that he had made a full and complete settlement of his claims. Petitioner alleged that the purported release was void because he had signed it relying on
    Respondent’s deliberately false statement that the document was nothing more than a receipt for back wages. At trial, the jury found in favor of the Petitioner and awarded him $25,000. The trial judge later entered judgment notwithstanding the verdict. The judgment notwithstanding the verdict was reversed by the Court of Appeals of Summit County, Ohio. The Supreme Court of Ohio reversed the judgment of the court of appeals and sustained the trial court’s action.

    Issue. Should the validity of the release be governed by federal or state law? If it is state
    law, then did Ohio correctly apply the standard?

    Held. The validity of releases under the Act raises a federal question to be determined by
    federal rather than state law. State laws do not control or determine what a federal statute or right entails. The purpose of the Act would be defeated if states could determine what certain person’s rights were under the federal statute. Further, a release of rights under the
    Act is void when the employee is induced to sign it by the deliberately false and material statements of the employer’s representatives. In Ohio, factual questions of fraudulent releases are separated, with some issues tried to the jury, and others to the judge. The right to a jury trial is a fundamental right, which should not have been denied in a state court as it was here. The trial judge and the Supreme Court of Ohio erred in holding that petitioner’s rights were to be determined by Ohio law and in taking away Petitioner’s verdict when the issues of fraud had been submitted to the jury on conflicting evidence
    and determined in Petitioner’s favor.

    Dissent. Justice Frankfurter, with whom Justice Reed, Justice Jackson and Justice Burton join, concurred for reversal, but dissented from the court’s opinion. The dissent
    noted that there should be no distinction between other negligence actions, routinely handled under state law, and the negligence alleged in this situation under a federal act.

    Discussion. This decision is rooted in the fact that if federal law controls then it should
    be given uniform application through the country. This is essential to effectuate the purpose of federal statutes.


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