Edwards v. Pacific Fruit Express Co.

Background

The case involves Pacific Fruit Express Company, a nationwide refrigerator-car company that owns, leases, and repairs insulated railroad cars, and Edwards, an iceman who worked at the company’s repair and concentration plant. Edwards was injured while driving a company motor vehicle carrying ice to store in cars and sued the company, saying it was a “common carrier by railroad” covered by the Federal Employers’ Liability Act. The District Court granted summary judgment for the company, the Court of Appeals affirmed, and the Supreme Court agreed to review and ultimately affirmed the lower courts.

Reasoning

The central question was whether a company that rents and services refrigerator cars is an operating railroad under the Act. The Court relied on older decisions holding that a “common carrier by railroad” means one who operates a railroad as a means of carrying for the public, and it emphasized that activities like renting cars, repairing them, and running repair yards are not the same as operating a going railroad. The opinion reviewed legislative history, noting Congress considered but rejected broadening the Act in 1939 and had expressly included refrigerator car companies in other statutes but not in the Employers’ Liability Act. Courts for sixty years had treated refrigerator car companies as outside the Act.

Real world impact

Because the company is not covered by the Act, injured employees like Edwards cannot sue under the Federal Employers’ Liability Act and must look to state workers’ compensation systems; Edwards had already received over $6,000 under California law. The Court declined to change long-standing practice and left any expansion of coverage to Congress.