Chicago & North Western Railway Co. v. Bolle

Background

A railroad company employed a worker to fire a stationary engine that produced steam used to heat a passenger depot, baggage room, some coaches, and employee bunk cars in Waukegan, Illinois. When the stationary engine failed, the worker used a locomotive as a temporary substitute and was sent about four miles to get coal. While coal was being loaded onto one locomotive, he was seriously injured and sued under the Federal Employers’ Liability Act, the federal law that allows railroad employees to recover for work injuries tied to interstate transportation. The case went through multiple trials and state appeals before reaching this Court.

Reasoning

The central question was whether the worker’s task—firing an engine only to produce steam for heating—was part of interstate transportation. The Court applied the established test from earlier cases: to be covered, an employee must be engaged in interstate transportation or in work so closely related to it that it is practically part of it. The Court found that producing steam for station heating was not transportation and was no more closely related to interstate movement than tasks previously held not to qualify. Relying on prior decisions that excluded similar heating and shop duties, the Court concluded the worker was not performing interstate transportation work when injured.

Real world impact

The ruling means tasks devoted solely to station heating and similar depot services are unlikely to qualify as interstate transportation under the federal law, limiting recovery for workers in those roles. The Court reversed the lower judgment and held the employee outside the Act’s protection.