Miles v. Illinois Central Railroad

1942-04-27

Headline: State court cannot block residents from suing a railroad in another state under F.E.L.A.; Court reverses Tennessee injunction and allows suits where the railroad does business.

Holding: The Court held that under §6 of the Federal Employers' Liability Act, a state may not enjoin its residents from prosecuting a F.E.L.A. suit in another state's court when the railroad does business there and venue is proper.

Real World Impact:

Stops states from enjoining citizens from pursuing F.E.L.A. suits in other states where carrier does business.
Makes it easier for injured workers and survivors to sue where the railroad operates.
Restricts state courts from using equity to block federally authorized venue choices.

Topics: workplace injury, railroad liability, state court injunctions, venue rules

Summary

Background

An Illinois railroad company sued in Tennessee chancery court to stop a Tennessee widow, Mrs. Miles, and the decedent’s children from pursuing a Federal Employers' Liability Act (F.E.L.A.) wrongful-death suit that had been filed in Missouri. The husband died in Memphis. After an initial temporary injunction the widow dismissed the Missouri case and a Missouri administrator refiled. The Tennessee trial court issued temporary injunctions citing inconvenience, expense, and burdens on the carrier’s commerce; the Tennessee Court of Appeals later made those injunctions permanent.

Reasoning

The Supreme Court examined §6 of the F.E.L.A., which gives concurrent jurisdiction to state courts and bars removal of properly brought state actions to federal court. The Court found Missouri could lawfully be used because the railroad did business there. Relying on §6 and the Constitution’s guarantee that federal laws are enforceable in state courts, the Court held that a state may not use its courts to stop its citizens from exercising the federal privilege to sue in another state’s court where venue and jurisdiction are proper. The Court did not address whether the litigation posed a burden on interstate commerce because that issue was not found or was abandoned below.

Real world impact

The ruling prevents a state from barring its residents from pursuing F.E.L.A. claims in sister-state courts when the carrier is doing business there. Injured railroad workers and survivors can more reliably choose forums where the railroad operates. The decision reverses the Tennessee appellate judgment and sends the case back for further proceedings consistent with the opinion.

Dissents or concurrances

Justice Jackson concurred, agreeing with reversal but noting concerns about forum shopping and limiting his view that Missouri must be compelled to entertain the case. Justice Frankfurter dissented, arguing longstanding state equity powers to enjoin oppressive suits were not displaced by §6 and should be preserved.