Stone v. New York, Chicago & St. Louis Railroad

Background

A railroad section worker was helping remove old track ties when his back was badly injured. Supervisors usually had two men pull ties with tongs, but stubborn ties sometimes needed three or four men or other methods like digging a trench, jacking the rail, or temporarily unfastening the rail. On the day of the injury the foreman told the worker to pull harder despite the worker saying he was already pulling as hard as he could; the tie later proved to have a spike into the ground. A jury returned a verdict for the worker, but the Missouri Supreme Court overturned it.

Reasoning

The Court addressed whether the facts created a real question of negligence and causation suitable for a jury. Justice Douglas said the test is what a reasonable person would do and that the foreman had extra men and safer alternatives available. The worker warned he could not pull harder and was ordered to continue. The Court found this evidence enough to let a jury weigh whether the supervisor acted negligently and caused the injury, so it reversed the state court’s decision.

Real world impact

This ruling means similar workplace disputes about risky orders and available safer methods can go before juries. Railroad and other manual labor workers who protest strain may have stronger grounds to have claims decided by jurors rather than being dismissed early. The decision does not change final liability rules but affects whether cases reach a jury.

Dissents or concurrances

Three Justices disagreed, arguing state courts should be respected when reasonable judges differ about whether evidence is enough to send a case to a jury.