Jesionowski v. Boston & Maine Railroad
Headline: Court reverses lower court and allows juries to infer a railroad’s negligence from an unusual train derailment, even when the injured worker took part in operations, if evidence shows the worker didn’t cause the crash.
Holding: The Court held that juries may infer negligence from an unusual accident in a railroad worker’s death, despite the worker’s participation, provided the evidence shows the worker’s actions did not cause the derailment.
- Permits juries to infer company negligence from unusual accidents when employee actions didn’t cause them.
- Makes it harder for defendants to block jury verdicts by claiming lack of exclusive control.
- Applies to federal workplace-death cases under the Federal Employers’ Liability Act.
Summary
Background
A family member sued a railroad under the Federal Employers’ Liability Act after a brakeman was killed when four cars were being shoved backward and derailed. The complaint alleged a defect in the car, track, or roadbed and general negligence. The trial judge took one claim from the jury and submitted the other; the jury returned a verdict for the family member, but the federal Court of Appeals reversed and ordered judgment for the railroad.
Reasoning
The main question was whether a jury may infer a carrier’s negligence from an unusual accident when the injured worker also participated in the operation. The Court explained that the rule allowing such an inference means the facts justify the inference, not that the inference is forced. The Court reviewed evidence about a switch, a frog with a spring, and scattered planks and splinters. Because the jury could find the employee’s actions did not cause the derailment, the railroad remained the only other agency that might have caused it, and the jury could reasonably infer negligence by the railroad.
Real world impact
The decision lets juries draw negligence inferences in federal workplace-death cases involving unusual accidents, even where the injured employee did some of the work, provided the evidence shows the employee did not cause the accident. This gives injured workers’ families a clearer path to jury consideration in similar railroad and other federal negligence trials.
Dissents or concurrances
Three Justices would have affirmed the Court of Appeals’ ruling and denied the jury’s inference on the reasoning stated in that lower-court opinion.
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