Ryland S. Felts v. Seaboard Coast Line Railroad Company

1972-10-16

Headline: Railroad workers’ injury appeals under the Federal Employers’ Liability Act denied as the Court refuses review, leaving lower-court rulings intact and preventing reinstatement of the jury awards for these employees.

Holding: The Court refused to review two railroad employees’ injury cases and denied their petitions, leaving the lower courts’ rulings in place and keeping the appellate judgments unaltered while no new ruling was issued.

Real World Impact:

Leaves appellate court decisions intact, so these employees lose their jury verdicts.
Affirms lower courts’ finding that prior settlement or release may bar recovery in some injury suits.
Keeps FELA questions for future resolution in lower courts unless the Court agrees to hear a new case.

Topics: railroad workplace injuries, workplace safety, injury lawsuits, jury trials for employees

Summary

Background

Adkins was a rail worker who lost part of his left leg while trying to repair a broken rail; his employer was a railroad owned by a mining company and a jury awarded him $117,568.44, but the trial judge granted the employer’s motion for judgment n.o.v. and the Court of Appeals affirmed. Felts was a Pullman conductor injured while opening a trap door on a Seaboard passenger train; a jury verdict for him was set aside by the trial court and affirmed on appeal. The Supreme Court was asked to review both appeals but denied the petitions.

Reasoning

The question presented was whether the Supreme Court would take these Federal Employers’ Liability Act cases for review. The Court declined and left the lower courts’ decisions intact. In a lengthy dissent Justice Douglas argued that under the Act any employer negligence, however slight, should be a question for the jury and that these issues — including whether a worker was effectively an employee of the railroad and whether a prior settlement or release barred recovery — should have been decided by juries.

Real world impact

Because the Court denied review, the appellate rulings that set aside jury verdicts remain in effect for these plaintiffs. That outcome means the injured workers do not regain their jury awards now, and similar FELA questions in other cases will continue to be litigated in lower courts unless the Supreme Court takes a future case. One case note: Justice Powell did not participate in the Felts consideration.

Dissents or concurrances

Justice Douglas strongly dissented, saying these denials undercut the remedial purpose of the statute and urging that the Court should have granted and reversed or at least heard argument to preserve jury protections for railroad employees.