Moore v. Terminal Railroad Assn. of St. Louis

Background

A baggage handler employed by a St. Louis railroad was injured on a narrow loading platform between tracks when a long hand cart he was pulling swung into a moving train and threw him against a standing car. The platform, roof supports, other carts, and the size and movement of the cart are described in detail in the record. The worker sued, claiming the railroad’s negligence contributed to his injuries under the Federal Employers’ Liability Act.

Reasoning

The central question was whether the evidence was enough to let a jury decide that the employer’s negligence played at least some part in causing the injury. The Court, speaking per curiam, held that the proofs “justified with reason” the jury’s finding that employer fault contributed to the accident, reversed the Missouri Supreme Court’s judgment, and sent the case back for further proceedings consistent with this opinion. Several earlier decisions are cited, and Justices Harlan, Frankfurter, Whittaker, and Burton expressed separate views.

Real world impact

The ruling means that when the record contains similar physical facts, courts should not automatically take negligence questions away from juries; a jury may decide whether an employer’s actions helped cause an employee’s injury. The case was reversed and remanded, so further proceedings will follow in the lower court rather than ending the claim.

Dissents or concurrances

Justice Harlan concurred in the result; Justice Frankfurter thought certiorari should not have been granted. Justice Whittaker (joined by Justice Burton) dissented, arguing the record showed only the employee’s own negligent act and no employer negligence.