Maynard v. Durham & Southern Railway Co.

Background

A railroad worker sued his employer for injuries under the Federal Employers' Liability Act after a workplace accident on August 22, 1955. He returned to work in September and on September 17 signed a release and received a $144.60 check. The worker said he thought he was signing for a regular pay check; the company said it paid him in settlement only if he signed a release. The trial court dismissed the suit on the release, and the North Carolina Supreme Court affirmed.

Reasoning

The Supreme Court reviewed whether federal law governs the validity of releases under the federal railroad statute and whether the release had adequate consideration. The Court found no evidence of fraud, but concluded the record contained conflicting evidence about whether the money paid was wages already owed or new consideration for the release. Citing federal standards, the Court held that whether the release was supported by something the worker had no prior right to receive is a question for a jury, not the judges, and reversed the state court ruling.

Real world impact

The ruling means disputed releases in railroad-injury cases must be tested by juries when evidence conflicts about payment versus wages. It applies federal law to these release questions and prevents courts from treating disputed factual issues about consideration as settled law. Because the case was reversed and sent back for factual determination, the final outcome still depends on further proceedings.

Dissents or concurrances

Three Justices argued the Court should not have granted review to decide a factual dispute and would have affirmed, saying the record supported enforcement of the release.