Rogers v. Missouri Pacific Railroad

Background

A railroad laborer assigned to burn weeds along a double-track line used a small hand torch while standing on a narrow dirt path near the tracks. A passing train fanned the burning vegetation, enveloped him in smoke and flames, and he slipped from a nearby culvert and was seriously injured. He sued the railroad under the Federal Employers’ Liability Act, a federal law that lets railroad workers recover when employer negligence plays any part in an injury. A jury awarded him damages, but the Supreme Court of Missouri reversed, saying the evidence did not support the railroad’s liability.

Reasoning

The Supreme Court considered whether the state court improperly took the question away from the jury. The Court explained that, under the federal law, the proper test is whether employer negligence played any part, however small, in causing the injury. The Court found evidence — including the change from usual track-based flame throwers to a man with a hand torch and the worker’s orders to watch trains — that a jury could reasonably find employer negligence contributed to the accident. Therefore the Court reversed and sent the case back for further proceedings.

Real world impact

The ruling preserves the jury’s role in workplace injury cases and makes it easier for injured railroad employees to have juries decide whether employer fault contributed at all. Employers face greater risk that close-call causation questions will be left for juries, not judges. The case was sent back to the lower court for further steps consistent with this opinion.

Dissents or concurrances

Justices disagreed about the outcome: one Justice concurred in the result, another would have affirmed the Missouri court, and other Justices wrote separate opinions disagreeing with the majority’s view on the standard for taking a case from a jury.