Hay v. May Department Stores Co.

Background

A Missouri worker sued his employer’s New York corporation and a co-worker in a St. Louis state court after a workplace accident involving loaded trucks. The worker said both the company’s unsafe conditions and the co-worker’s reckless pushing of a truck combined to cause the injury. The company asked to move the case to federal court, claiming a separable dispute existed between the out-of-state corporation and the injured worker. The state court allowed removal and the federal court denied the worker’s motion to send the case back.

Reasoning

The central question was whether the federal court could take the case because there was a “separable controversy” between citizens of different states. The Court explained longstanding rules: when a complaint in state court alleges that two defendants’ negligent actions jointly caused harm, that is a joint case, not a separable dispute. Because the worker’s petition said the company’s and co-worker’s negligence acted together, the company’s removal petition did not show a separable controversy and could not create federal-court authority to hear the case.

Real world impact

The Court reversed and ordered the case sent back to the state court. The decision keeps similar workplace-injury suits alleging joint fault in state courts and limits companies’ ability to force such cases into federal court. This ruling addresses only who hears the case, not the merits of the worker’s injury claims.