Dice v. Akron, Canton & Youngstown Railroad

Background

A railroad fireman was badly hurt when his engine jumped the track. He sued his employer under the Federal Employers' Liability Act, claiming negligence. The railroad pointed to a signed document that it said released all claims for $924.63, but the worker said he signed only because company agents lied that the paper was a wage receipt. A jury awarded the worker $25,000, but the trial judge set aside that verdict and the Ohio Supreme Court later enforced state rules holding the release valid and letting a judge decide fraud issues.

Reasoning

The Court faced whether federal or Ohio law decides when a railroad worker's settlement release is valid and who should decide fraud. The majority said federal law governs releases under the federal injury law so the rule must be uniform nationwide. It held a release is void if an employer's authorized representatives deliberately misled the employee about the document's contents. The Court also protected the worker's jury verdict, finding Ohio erred in taking that verdict away.

Real world impact

The decision means injured railroad workers nationwide cannot be denied recovery by secretive releases obtained through deliberate lies by employer agents. It preserves the right to have disputed fraud questions decided by a jury rather than a judge alone. The case was sent back to Ohio's courts for further action consistent with the Supreme Court's rulings, so some proceedings will continue there.

Dissents or concurrances

One Justice agreed the verdict should be returned but disagreed with using federal rules to change which factfinder states may use; he warned against overturning long-standing state procedures and questioned the trial judge's wording about the burden of proof.