CSX Transportation v. McBride

PETITIONER: CSX Transportation, Inc.
RESPONDENT: Robert McBride
LOCATION: CSX Transportation

DOCKET NO.: 10-235
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the Seventh Circuit

CITATION: 564 US (2011)
GRANTED: Nov 29, 2010
ARGUED: Mar 28, 2011
DECIDED: Jun 23, 2011

ADVOCATES:
Charles A. Rothfeld - for the petitioner
David C. Frederick - for the respondent

Facts of the case

Locomotive engineer Robert McBride filed suit after contending that he injured his hand while adding and removing railroad cars for his employer, CSX Transportation, Inc. Under the Federal Employers' Liability Act, a rail carrier is liable for worker injuries that result from negligence by the carrier. A trial judge instructed the jury that CSX caused or contributed to McBride's injury if its negligence "played a part, no matter how small, in bringing about the injury." The jury found for McBride and awarded him $184,250.

CSX argued that McBride should have been required to prove that the company's alleged negligence was a cause of the injury. But the U.S. Court of Appeals for the Seventh Circuit disagreed, affirming the verdict.

Question

Does the Federal Employers' Liability Act require proof of proximate causation?

Media for CSX Transportation v. McBride

Audio Transcription for Oral Argument - March 28, 2011 in CSX Transportation v. McBride

Audio Transcription for Opinion Announcement - June 23, 2011 in CSX Transportation v. McBride

Ruth Bader Ginsburg:

The second case I have is CSX Transportation v. McBride.

This case concerns the causation standard applicable in lawsuits under the Federal Employers' Liability Act, today properly known as FELA.

Enacted in 1908, FELA renders railroads liable for a worker's injury or death resulting in whole or in part from the railroads negligence.

The question before us, does FELA incorporate by the Act's silence stock proximate cause formulations developed in common law tort actions, for example, in ones -- was in buggy and now automobile accident cases.

Or should get us causation instructions instead speak to the jury in the language of the statute?

The term proximate cause, first year law students learn, expresses in shorthand the concept that injuries have countless causes but those stretching that too far should not give rise to legal liability.

Common law courts having employed many different verbal formulations to convey to juries just what proximate cause means.

Often those formulations are restrictive.

For example, juries have been told that a plaintiff cannot recover if the causal link between defendant's conduct and plaintiff's injury was insufficiently substantial or if there was any intervening cause or if the relationship between cause and injury was not direct or natural or probable.

We hold that none of those formulations express the proper feel or causation standard.

The plaintiff in this case, Robert McBride, was injured while performing a switching operation for his employer CSX Transportation, an interstate railroad, and the petitioner here.

Alleging that CSX had provided unsafe equipment and inadequate training, McBride sued the railroad in Federal District Court in Illinois seeking compensation under FELA.

A verdict for McBride was in order, the District judge instructed, if the jury found that CSX was negligent and that the railroad's negligence cause or contributed to McBride's injury.

The railroad sought an additional instruction requiring McBride to show that the railroad's negligence was a proximate cause of his injury.

If the railroad proposed to define proximate cause to mean any cause, which in natural or probable sequence produced the injury complained off.

The District Court refused to give the instructions CSX requested and instead the District Court read to the jury, the Seventh Circuits have an instructions for causation in FELA cases.

Defendant -- defendant caused or contributed to plaintiff's injury, if defendant's negligence played a part no matter how small in bringing about the injury.

The jury returned a verdict for McBride.

On appeal the railroad contended that the District Court should have instructed the jury as CSX requested on proximate causation.

The Seventh Circuit disagreed and affirmed the judgment entered on the jury's verdict.

The Appeals Court explained that the causation instruction the District Court gave paraphrase language from this Court's 1957 decision in Rogers v. Missouri, Missouri Pacific Railroad.

Roger stated under FELA, the test of the jury case is simply whether the proofs justified the conclusion that employer negligence played any part even the slightest in producing the injury.

We agree with the Seventh Circuit that FELA does not incorporate staff proximate cause instructions developed in non-statutory common law tort actions and we therefore affirmed the Court of Appeals judgment.

The railroad urges that Rogers addressed only the problem of injuries with multiple causes typically plaintiffs own negligence as well as the defendant's lack of due care.

For reasons set out only in the Court's opinion, we reject that in our reading and instead read Rogers to state comprehensively -- and comprehensively, the FELA causation standard for all cases.

Our understanding of FELA's causation standard tracks, the Acts text and is consistent with the legislation's history.

It also accords with the view of every Federal Court of Appeals that reviews FELA cases.

Failing to instruct on proximate cause, CSX worries will invite juries to impose limitless liability on railroads.

We see little cause for that concern, instructions like the one given at -- in McBride's case have been read to juries in countless cases over the last 50 years.

Yet the railroad road was unable to identify even a single trial in which such an instruction generated and outlined this award.