New York Central Railroad v. Marcone

Background

A man who worked in a railroad roundhouse was killed when an engine was backed out at night. The worker’s representative sued the railroad under the Federal Employers’ Liability Act, saying the railroad was negligent in moving the engine without adequate warning. The jury found for the representative, and New Jersey’s highest court affirmed, leading to review by the Supreme Court.

Reasoning

The Court addressed whether there was enough evidence both that the worker’s presence was related to interstate commerce and that the railroad was negligent. The opinion notes facts a jury could rely on: the worker’s duties inspecting engines in the roundhouse, the engine’s close clearance, the tender blocking the view, warning whistles and bells that were often sounded, a posted time that did not match the actual removal time, and evidence the engine was moved earlier than posted. The Court concluded these facts were sufficient for a jury to find the railroad failed to give a specific, effective warning and that the worker’s presence was an incident of interstate commerce, so the case could go to the jury. The Court also confirmed that contributory negligence does not bar recovery unless it was the sole cause.

Real world impact

The decision allows recovery under federal railroad employer-liability law when a worker’s on-site presence is closely tied to interstate work and there is evidence of insufficient warning. It leaves factual questions to juries about negligence and whether a worker’s actions were the sole cause of an injury.