LOCATION: Seminole Tribe
DOCKET NO.: 95-6
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: State appellate court
CITATION: 516 US 400 (1996)
ARGUED: Jan 08, 1996
DECIDED: Feb 27, 1996
Carter G. Phillips - Argued the cause for the petitioner
Lawrence M. Mann - Argued the cause for the respondent
Facts of the case
Railroad cars are connected by couplers consisting of knuckles - clamps that lock with their mates - joined to the ends of drawbars, which are fastened to housing mechanisms on the cars. Cars automatically couple when they come together and one car's open knuckle engages the other car's closed knuckle. The drawbar pivots in its housing, allowing the knuckled end some lateral play to prevent moving cars from derailing on a curved track. As a consequence of this lateral movement, drawbars may remain off-center when cars are uncoupled and must be realigned manually to ensure proper coupling. William J. Hiles injured his back while attempting to realign an off-center drawbar on a car at one of Norfolk & Western Rail Company's yards. Hiles sued in Illinois state court, alleging that Norfolk & Western had violated Section 2 of the federal Safety Appliance Act (SAA), which requires that cars be equipped with "couplers coupling automatically by impact, and capable of being uncoupled, without the necessity of individuals going between the ends of the vehicles." The trial court granted Hiles a directed verdict on liability, and the state appellate court affirmed.
Is a railroad liable, under the federal Safety Appliance Act, for injuries incurred by a railroad employee while trying to straighten a misaligned drawbar?
Media for Norfolk & Western Railway Company v. HilesAudio Transcription for Oral Argument - January 08, 1996 in Norfolk & Western Railway Company v. Hiles
Audio Transcription for Opinion Announcement - February 27, 1996 in Norfolk & Western Railway Company v. Hiles
The second case I have to announce is a bit more obvious, it is a Norfolk and Western Railway Co. versus Hiles, No. 95-6.
This case comes to us on writ of certiorari to the Illinois Appellate Court for the Fifth Judicial District.
Railroad cars are connected by couplers located in both ends of each car.
The couplers attached to a housing mechanism on the car by drawbar that is designed to have some lateral plate to prevent moving cars from the derailing on a curved track.
As a result of this lateral movement, drawbars may remain off-center when cars are uncoupled and must be realigned manually to ensure proper coupling.
Respondent William Hiles injured his back while attempting to realign an off-center drawbar and sued petitioner Norfolk and Western Railroad Company in Illinois State Court arguing that the misaligned drawbar was a violation of Section 2 of the Federal Safety Appliance Act.
This law prohibits railroads from using cars that are not equipped with couplers that will automatically couple on impact and uncoupled without the necessity of employees going between the cars.
The Trial Court ruled in favor of Hiles and the Appellate Court affirmed.
We now reverse.
Hiles argues that the statute was violated because the car would not couple until he realigned the drawbar and he could not do that without going between the cars.
We disagree primarily because the language of Section 2 requires only that railroads equip their cars with standardized automatic couplers.
Section 2 does not independently prevent railroad employees from going between railcars.
We have previously recognized that employees must take certain preliminary steps to ensure proper performance of automatic couplers before a court can find a violation of Section 2 and today we hold that realigning a misaligned drawbar is one of those preliminary steps.
We decline to adapt an interpretation of Section 2 that suggest a misaligned drawbar is by definition a malfunctioning drawbar nor can we accept Hiles suggestion that Section 2 required the railroads to develop new technology for automatic realignment.
The judgment of the Illinois Appellate Court is reversed.
The opinion of the Court is unanimous.