New York Central Railroad v. United States

Background

The federal government sued a railroad company under the Safety Appliance Acts to recover penalties after trains ran from Coalburg, Ohio to Buffalo, New York with some cars whose air brakes had failed and been cut out. One train had 63 cars and three defective air-braked cars; another had 80 cars with a similar problem. Repair crews and materials were available at Erie, but the railroad ran the trains past that repair station while the defective cars remained in the train and in the air line.

Reasoning

The Court addressed whether it was lawful to operate a train past an available repair station when some cars originally equipped with power (air) brakes had become defective and been cut out of the air line. The Court explained that the statutes treat only two classes—cars equipped with power brakes and cars with hand brakes only—and that cars originally power-braked do not stop being in that class merely because their brakes temporarily failed and were cut out. Because those defective cars remained in the air line and were associated with the other power-braked cars, the statute required their brakes to be operated by the engineer; running the train in that condition violated the law. The Court added that placing such defective cars at the rear so they are not associated with the engineer-operated power-brake group would avoid a violation.

Real world impact

The decision requires railroads to either move defective power-braked cars to the rear or repair them at an available station rather than simply cutting them out and continuing with those cars interspersed, affecting how trains are handled to protect safety.