Parden v. Terminal Railway of Alabama State Docks Department

Background

A group of Alabama railroad employees sued the Terminal Railway, which is owned and operated by the State of Alabama, for injuries sustained while working and sought damages under the Federal Employers' Liability Act. The Terminal Railway runs about fifty miles of track near Mobile, serves the state docks and local industries, has labor agreements, follows federal safety rules, and engages in interstate commerce. The State claimed sovereign immunity and the lower courts dismissed the suit.

Reasoning

The Court asked whether the FELA applies and whether Congress can make a State liable for suits when the State operates a railroad in interstate commerce. The majority held that the FELA covers "every" common carrier in interstate commerce and that federal railroad laws have long applied to state-owned lines. Because the power to regulate interstate commerce allows Congress to attach conditions to its exercise, the Court concluded Alabama, by operating an interstate railroad, accepted the condition of being subject to FELA suits. The result lets the employees proceed in federal court.

Real world impact

State-owned railroads that operate in interstate commerce can be sued under the FELA like private railroads. Injured employees of state railroads can bring federal lawsuits to recover damages. This ruling reduces a gap where state ownership previously might have blocked enforcement of federal employee protections.

Dissents or concurrances

A dissent warned that finding a waiver of state immunity should require clear, express congressional language; it argued courts should not infer waiver from general statutory terms.