Breisch v. Central R. Co. of NJ

Background

A Pennsylvania railroad worker was injured in Pennsylvania when his employer failed to provide an efficient hand brake on a car. He sued at common law in federal court under the Federal Safety Appliance Acts. The federal trial court ruled for him, but the Circuit Court of Appeals reversed, holding his only remedy was under Pennsylvania’s Workmen’s Compensation Act.

Reasoning

The Court examined whether Pennsylvania law confines recovery for federal safety-law violations to the state compensation system. It reviewed prior Pennsylvania decisions, especially Miller, where the state’s highest court had interpreted the Compensation Act as not covering claims that enforce rights created by federal safety statutes. Noting the state legislature had not changed that interpretation, the Justices concluded federal courts must follow the state court’s construction of its own law. The majority therefore let the injured worker pursue a court action for damages under the federal safety law.

Real world impact

The decision means that in Pennsylvania, railroad employees hurt by defective equipment can seek damages in court under federal safety statutes when the state’s courts have said the Compensation Act does not cover those federal claims. The ruling rests on Pennsylvania’s particular statutory interpretation and does not itself rewrite federal safety rules or require the same result in other states.

Dissents or concurrances

Justice Roberts disagreed and would have affirmed the Circuit Court of Appeals, keeping the worker’s remedy limited to the state compensation system.