Urie v. Thompson

Background

Tom Urie, a longtime fireman on Missouri Pacific steam locomotives, stopped work in 1940 after being diagnosed with silicosis from years of inhaling silica dust. He alleged the railroad used sand with about 80–90% silica, that sanding equipment was faultily adjusted so excess sand produced dust, and that cracked cabs let dust into the engine cabs. Urie sued in 1941, initially under the Federal Employers’ Liability Act (FELA); after an intermediate ruling he amended to add the Boiler Inspection Act. A jury returned a $30,000 verdict for Urie, but the Missouri Supreme Court reversed on appeal saying the Boiler Inspection Act covered only accidental injuries.

Reasoning

The Supreme Court asked whether an occupational disease like silicosis qualifies as an “injury” under FELA and the Boiler Inspection Act and when the statute of limitations begins. The Court held that the broad language and humanitarian purpose of FELA include occupational disease caused by employer negligence. It rejected treating every inhalation as a separate cause of action and held the limitations period runs from the time the disease manifests and incapacitates (here May 1940). The Court also explained that Boiler Inspection Act violations and Interstate Commerce Commission rules (including Rule 120 on sanders) supplement FELA by showing equipment defects; on the record the jury reasonably found a breach and proximate cause.

Real world impact

Railroad employees who develop occupational diseases can bring FELA claims and may rely on Boiler Inspection Act violations to prove carrier responsibility. Railroads can be held liable for defective equipment, poor maintenance, or practices that create harmful dust exposure. The Court reversed the state court and reinstated Urie’s verdict.

Dissents or concurrances

Justice Frankfurter agreed FELA covers occupational disease but would not extend the Boiler Inspection Act to cover disease and urged legislative reform instead.