Still v. Norfolk & Western Railway Co.

Background

A railroad worker sued Norfolk & Western Railway seeking damages for back injuries he said the railroad negligently caused. The railroad argued he was not really an "employee" under the law because he had lied about his health when hired and that those lies helped cause his injury. A trial judge directed a verdict for the railroad, and state courts upheld that result, so the worker appealed to the Supreme Court to decide how the federal law should apply.

Reasoning

The central question was whether a worker who obtained a job by false statements can be stripped of the special protections the Federal Employers’ Liability Act gives to railroad employees. The Court held that the old Rock decision — which denied recovery to an impostor who obtained work by an extreme scheme — must be confined to its narrow facts. Except for that precise impostor situation, people who became railroad employees despite some hiring misrepresentations count as "employees" under the Act. The Court rejected treating many lies as an automatic bar to recovery and said issues of causation or fraud generally should not override Congress’s policy of compensating injured railroad workers.

Real world impact

The decision means most injured railroad workers who lied when hired will still be treated as employees for purposes of recovery, though evidence about a worker’s prior condition can affect causation or damages. Trial courts must not grant blanket dismissals based on ordinary hiring misstatements; many disputes will go back for jury consideration or new trials.

Dissents or concurrances

Justice Frankfurter agreed a new trial should be held and that the jury should decide facts. Justice Whittaker dissented, arguing that flagrant hiring fraud should bar the special benefits of the Act.