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N.Y. Central R.R. Co. v. White

    Brief Fact Summary.

    Jacob White was employed by Defendant when White died due to a work related injury. White’s widow, Plaintiff, brought suit-seeking compensation under New York’s Workmen’s Compensation Law. The lower court awarded Plaintiff her remedy, and Defendant appealed. The appellate court affirmed the lower court’s ruling, and Defendant petitioned for certiorari.

    Synopsis of Rule of Law.

    When a state workmen’s compensation scheme is an adequate and reasonable remedy for a fault-based lawsuit, the mere fact that the scheme provides an exclusive source of compensation for an employee’s injury or death during the course of employment, without regard to fault, does not constitute a Fourteenth Amendment violation.

    Facts.

    Jacob White was an employee at the New York Central & Hudson River Railroad Company, Defendant. White died due to an accident that he sustained in the course of his employment with Defendant. White’s widow, Plaintiff, brought suit seeking compensation under New York’s Workmen’s Compensation Law. Under the Workman’s Compensation law, Plaintiff was entitled to an exclusive remedy for employee injury and death during the course of employment, without regard to fault. Thereafter, Plaintiff was awarded relief and the New York Court of Appeal affirmed the award. Defendant filed a petition for certiorari in the Supreme Court of The United States alleging that the Workmen’s Compensation Law took Defendant’s property in violation of due process under the Fourteenth Amendment.

    Issue.

    Does the mere fact that the state workmen’s compensation scheme provides an exclusive source of compensation for an employee’s injury or death during the course of employment, without regard to fault, constitute a Fourteenth Amendment violation when the scheme is an adequate and reasonable remedy for a fault-based lawsuit?

    Held.

    No, the mere fact that the state workmen’s compensation scheme provides an exclusive source of compensation for an employee’s injury or death during the course of employment, without regard to fault, constitute a Fourteenth Amendment violation when the scheme is an adequate and reasonable remedy for a fault-based lawsuit?

    Discussion.

    New York’s Workmen’s Compensation Law does not infringe on the Fourteenth Amendment. The legislature establishes and modifies laws as it sees fit. Thus, individuals lack a reasonable interest in the prolonged operation of any particular law, including the common law. Likewise, states have the authority to regulate issues regarding safety, which includes the responsibility for employers to compensate employees for injury or death that results from employment. In this case, the Court finds that it is not unreasonable for a state to require an employee compensation for death or injury, even without considering the fault of either party with a compensation schedule. Despite the fact that a workmen’s compensation scheme may remove the employers and employees ability to obtain a legal judgment, the system is beneficial to both parties because it establishes a particular and limited remedy. Therefore, the decision of the appellate court is affirmed. 


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