Swinson v. Chicago, St. Paul, Minneapolis & Omaha Railway Co.

Background

Swinson, a freight brakeman, sued his railroad under a federal law that allows railroad workers to recover for job injuries. While releasing a tightly set handbrake on a tank car, he put his left foot on the running board and his right foot against a grabiron — a round iron bar attached under the running board that stuck out a few inches. The plank split, a bolt pulled through, the grabiron failed, and Swinson fell in front of the moving car and was seriously hurt. The railroad argued the grabiron was meant only to be grasped by hand, not used as a foot brace. A trial judge directed a verdict for the railroad and the court of appeals affirmed; the Supreme Court granted review because the precise question had not been decided by the Court.

Reasoning

The Court examined whether the Safety Appliance Act’s command that cars be provided with "secure grab irons or handholds" covered the use that caused this injury. Relying on the Act’s broad construction and prior cases allowing recovery when statutory failures cause injury, the Court said an employee may recover if the defective appliance was a direct cause of the harm. There was evidence the grabiron might have been insecure even for hand use, and that using it as a foot brace was customary and did not appreciably increase strain. Given that evidence, the Court held it was error for the judge to remove the case from the jury because a jury could find the failed grabiron directly caused Swinson’s injury.

Real world impact

The ruling allows railroad workers to rely on grabirons for natural, customary uses, including as foot braces, and requires employers to keep those appliances secure. It sends the dispute back for a jury to decide the facts rather than ending the claim on a directed verdict. The decision reinforces a broad reading of the Safety Appliance Act to protect workers when a defective device causes injury.