Erie Railroad v. Duplak

Background

Michael Duplak, a five-year-old boy, lost a leg while on a railroad bridge built over a canal in Passaic, New Jersey. The track was used only to move freight cars into and out of sidings. At the time, the boy was kneeling and looking into the water with one leg extended under a line of cars; other cars were backed and ran over his leg. A warning sign forbade people from going on the bridge, and boys had sometimes played near the structure in warmer months. The boy and his parents sued the railroad in federal court, won a verdict, and the appeals court affirmed.

Reasoning

The Court relied on a New Jersey statute that makes it unlawful for anyone not employed by a railroad to walk along its tracks and bars recovery by anyone injured while walking, standing, or playing on a railroad. The state supreme court had interpreted that law to apply to all people without regard to age or physical condition. This Court found earlier state-court interpretations and a prior decision controlling, and concluded the statute prevented recovery here. The Court therefore did not resolve questions about negligence, invitation, or the attractive-nuisance idea because the state law, as construed, settled the issue against recovery.

Real world impact

Under this decision, New Jersey’s statute, as interpreted by the state courts, prevents injured trespassers from recovering damages when hurt on private railroad tracks or bridges. Railroads receive statutory protection from liability in similar circumstances, even when children had been known to play near the tracks and warning signs existed. Because the ruling rests on state statute and its interpretation, its reach depends on similar state laws and court constructions elsewhere.