Boston & Maine Railroad v. Armburg

Background

An employee was injured while working for an interstate railroad, but at the time he was performing only intrastate work. The employee sued to recover for his injuries. The railroad argued that common-law defenses — blaming a fellow worker or saying the employee assumed the risk — should apply, and it also argued that Massachusetts’s Workmen’s Compensation Act could not constitutionally be applied to an interstate carrier.

Reasoning

The Court addressed whether the state law, especially the insurance requirements and the rule denying certain employer defenses, unconstitutionally burdened interstate commerce when applied to an interstate carrier. The Massachusetts courts construed the statute to apply only to employees working within the state and not to reach areas governed by federal law. The Supreme Court accepted that construction, found no evidence that allocating payroll between intrastate and interstate work was impossible or necessarily burdensome, and said the railroad failed to prove the statute unconstitutional.

Real world impact

The decision means states can enforce their workmen’s compensation rules for local work done by nationwide carriers, provided the law is read not to invade fields already covered by federal law. Employers operating both inside and outside the State may have to insure their in-state operations or lose certain common-law defenses for injuries happening during intrastate service. The ruling rests on the state court’s narrowing construction and on the record’s lack of proof of an unconstitutional burden.