Chesapeake & Ohio Railway Co. v. Stapleton

Background

A 15-year-old Kentucky boy, employed as a section hand alongside his father who was his foreman and guardian, was sent to fetch water and passed between cars of a standing train on a switch track. The train moved while he was under the cars, he was run over, and suffered permanent injury. The railway employer was the Chesapeake and Ohio Railway Company, a Virginia corporation carrying interstate traffic in Kentucky. Kentucky law then forbade children under sixteen from working on railroads and prescribed criminal penalties for employers who violated that rule. The boy sued the railroad under the Federal Employers’ Liability Act; a jury awarded $17,500 and the Kentucky Court of Appeals affirmed.

Reasoning

The Court examined whether the state child‑labor statute could be treated as negligence in a federal suit under the Employers’ Liability Act. The opinion explained the federal Act makes negligence the basis for recovery and occupies the field of employer–employee liability in interstate railroading. The Kentucky statute was a criminal law with graduated penalties and showed no intent to define civil negligence for interstate carriers. Allowing the statute to substitute for the federal negligence inquiry would improperly apply state rules to a field governed by federal law. The Court therefore held the instruction that relieved the plaintiff of proving negligence was erroneous and reversed the judgment.

Real world impact

The ruling prevents state criminal child‑labor rules from automatically creating civil negligence in federal suits by employees working in interstate rail service. Injured interstate railroad workers must show negligence under the federal standard rather than rely on violation of a state prohibition. The opinion noted a different outcome might apply when a state rule fixes duties owed to the public or passengers, but for employer‑employee liability in interstate commerce federal law controls.