Brady v. Terminal Railroad Assn.

Background

A car inspector employed by a regional railroad was injured in 1927 while inspecting a freight car that another railroad had brought from St. Louis and placed on a receiving track at Granite City. The inspector grabbed a roof handhold attached to a rotten board, which gave way and caused his fall. He first sued his employer, then sued the railroad that had delivered and left the car. A Missouri court reversed a verdict for the inspector, and the Supreme Court took the case because of the federal safety law’s importance.

Reasoning

The Court addressed whether the delivering railroad still had responsibility when the car sat on the receiving track awaiting acceptance. It held the car was still “in use” and remained in the delivering railroad’s possession for statutory purposes. The Safety Appliance Act imposes an absolute duty to keep required equipment safe; that duty protects employees who must climb on cars to inspect them, even if they work for another railroad. The Court rejected the idea that inspecting for defects bars recovery and noted the statute removes the usual defense that an injured worker assumed the risk.

Real world impact

The ruling means railroads that leave cars on receiving tracks can be held liable for defective equipment that injures inspectors. It restores the inspector’s ability to recover under the federal safety law and requires carriers to keep equipment safe even while cars await acceptance. The case was reversed and sent back for further proceedings consistent with this opinion.