Boyd v. Grand Trunk Western Railroad

Background

An injured railroad worker accepted two small $50 advances from his employer after a 1946 workplace injury and signed agreements limiting where he could sue. The agreements said any lawsuit must be brought only in the county or federal district where he lived or where the injury occurred in Michigan. The worker instead filed suit in Cook County, Illinois, and the employer sued to block that Illinois case. State courts split on whether such venue-limiting contracts were valid, so the issue reached the Supreme Court.

Reasoning

The Court addressed whether a contract that restricts an injured worker’s choice of where to sue can stand under the Federal Employers’ Liability Act (the Act). The Act allows suit in several places — including where the defendant does business or where the cause arose — and Congress barred contracts that try to exempt carriers from liability. The Court held that the worker’s right to bring suit in any eligible forum is a substantial right protected by the Act, so contracts that limit that choice are void. The opinion distinguished lawful full settlements that end disputes from devices that try to defeat a plaintiff’s right to a judicial forum.

Real world impact

This ruling prevents employers from using small payments plus a signed agreement to force injured railroad workers into limited courts. Injured workers keep the right to sue in any court the Act allows, and employers cannot enforce post-injury venue waivers to avoid out-of-state suits. Two Justices agreed only on the result for different reasons, and two Justices did not participate in the decision.