CSX Transportation, Inc. v. McBride

Brief Fact Summary.

The Supreme Court of The United States held that railroads are liable under the Federal Employers Liability Act for any injury suffered by an employee “resulting in whole or in part from negligence.” 

Synopsis of Rule of Law.

All railroad companies are liable under the Federal Employers Liability act for any injury suffered by an employee during his employment, while performing his or her employment duties, when the railroad’s negligence to any degree played a part in the injury. 

Facts.

McBride was an engineer for CSX Transportation Inc. which primarily operated as a railroad company. One day, McBride seriously injured his hand on the job which required two separate surgeries. Unfortunately, McBride was unable to regain full use of his hand. As a result, he brought a negligence claim against CSX under the Federal Employers Liability Act. He alleged that the company did not properly train him to use the equipment and furthermore, he claims the equipment was unsafe for operation. At trial, a jury awarded McBride damages and CSX appealed. The appeals court affirmed the decision and the Supreme Court granted certiorari.

Issue.

Are railroad companies liable under the Federal Employers Liability Act for any injuries suffered by their employees in the course of their work as a result of the slightest negligence by the railroad company? 

Held.

Yes. The Federal Employer Liability Act protects all employees from any injuries suffered during the course of their work that was caused by even the slightest negligence by the employer. The Court held that only any form of negligence needs to be proved for an employee to recover. 

Dissent.

Disagrees with the notion that this act does not require proof of proximate cause.

Discussion.

The statute ignores the normal need for proximate cause but instead emphasizes the broad interpretation of the statute in order to protect employees from suffering costs as a result of being injured in the workplace.