New York, New Haven & Hartford Railroad v. Bezue

Background

A railroad worker employed at Maybrook, New York, was injured while helping move main driving wheels during a scheduled boiler-wash and repair. The worker had been on an unskilled labor gang and sometimes helped repair locomotives. The particular locomotive had arrived August 23 and been set aside for a monthly boiler-wash and extensive repairs that lasted twelve days. A New York court held the plant and the worker’s duties were part of interstate commerce and awarded a judgment under the federal employers’ liability law.

Reasoning

The core question was whether the worker’s activity counted as work “in interstate transportation” when the injury occurred. The Court said the correct test is whether the specific locomotive was in use in interstate transportation at the time, not simply where the employee worked or the general nature of the plant. Because the engine had been taken out of service for an extended boiler-wash and repairs, the Court concluded it was no longer an instrumentality of interstate commerce and reversed the state court’s judgment.

Real world impact

The decision narrows when federal employer-liability protections apply to railroad repair workers by focusing on the equipment’s actual service status at the time of injury. Employers, workers, and courts must look to whether a locomotive was withdrawn from interstate service when an accident occurred. The Supreme Court reversed the judgment and sent the case back for further proceedings consistent with its opinion.