Sinkler v. Missouri Pacific Railroad

Background\n\nA railroad cook was working on his employer's private car in Houston Union Station when a switching crew employed by the Houston Belt & Terminal Railway violently collided the car with another and injured him. The cook sued his railroad under the Federal Employers' Liability Act and won at trial, but a Texas appellate court reversed, saying the Belt Railway was an independent contractor, not the railroad's agent. The Supreme Court took the case to decide who must pay.\n\nReasoning\n\nThe Court said FELA's purpose is to protect railroad workers and to treat the railroad as a single enterprise whose resources should bear workplace losses. Given that goal, the word agents must be read broadly. The Belt Railway's crews were handling the railroad's cars to further the railroad's operations, so their work fit within the employer's enterprise even though the Belt Railway was a separate company. Corporate independence or lack of detailed supervision did not defeat liability under the Act. The Court therefore held that others performing a railroad's operational work under contract can be treated as the employer's agents for FELA claims.\n\nReal world impact\n\nAs a result, railroad employees injured by faults of contracted crews performing core operational tasks can recover from their employer under FELA. The decision reverses the Texas court's ruling and sends the case back for further proceedings consistent with this view. The ruling broadens who counts as an employer's agent in workplace injury claims under the Act.\n\nDissents or concurrances\n\nJustice Clark agreed with the outcome, calling the switching work nondelegable. Justice Whittaker said the injured cook was also a passenger, creating another nondelegable responsibility. Justice Harlan (joined by Frankfurter) dissented, warning that the Court was converting FELA into a compensation-style rule and that agents should keep their ordinary meaning.\n\n