New York, New Haven & Hartford Railroad v. Henagan

Background

A woman who worked as a waitress in a train’s grill car sued the railroad under the Federal Employers’ Liability Act for injuries she said came from a sudden, emergency brake application. The train stopped at Providence after a man stepped onto the track, apparently to commit suicide. A jury found for the waitress, and the trial court and the Court of Appeals upheld that verdict before the Supreme Court agreed to review the case.

Reasoning

The Court asked whether the record contained enough proof that the railroad’s negligence contributed to the emergency braking that allegedly caused the waitress’s injuries. After examining the trial record, the Court concluded the evidence was insufficient to let a jury decide that employer negligence played any part in the emergency stop. The Court therefore reversed the Court of Appeals and directed the trial court to enter judgment for the railroad notwithstanding the jury’s verdict.

Real world impact

In this case the jury’s verdict for the worker was replaced by a judgment for the railroad, showing that courts will not submit claims to juries without concrete proof that an employer’s negligence helped cause sudden train stops. The ruling affects injured railroad employees who rely on jury findings when the claimed injury follows an emergency caused by a third party.

Dissents or concurrances

Justices Black and Douglas dissented, saying they found enough evidence for a jury and that, if reversal was required, the proper remedy was a new trial rather than directing judgment for the railroad. Justice Frankfurter thought the Court should not have taken the case at all.