Duncan v. Thompson

Background

A railroad employee was injured on April 10, 1936 when he fell from a locomotive while working in interstate commerce. Because he worked for a common carrier engaged in interstate transport, his right to recover was governed by the Federal Employers’ Liability Act. On August 13, 1937 the railroad’s claim agent presented a written instrument and paid the injured worker $600 as an advance for living and other expenses, conditioned on his returning the money before filing suit. Negotiations later failed, and he sued in state court without repaying the $600; the trial court entered judgment for the worker but the state appellate court reversed.

Reasoning

The Court examined §5 of the Act, which declares void any contract, rule, regulation, or device that has the purpose of letting a carrier escape liability. Looking at the statute’s broad wording and congressional history, the Court concluded §5 covers agreements made after as well as before an injury. The Court found the instrument created a prerequisite to suing — effectively preventing most injured workers who accepted the advance from enforcing their rights — and it was not a genuine compromise or settlement, so the agreement was invalid.

Real world impact

The ruling prevents carriers from neutralizing the Act by using post‑injury payment deals that require repayment before a lawsuit can be filed. It protects injured railroad workers who accept short‑term help and preserves their ability to seek damages under the statute. The decision also resolves conflicting state-court views about such agreements and clarifies administration of the Act. One Justice (Roberts) did not participate in the decision.