Norfolk & Western Railway Co. v. Hiles

Background

A railroad worker, William J. Hiles, injured his back while manually realigning an off-center drawbar during switching work at Norfolk & Western’s yard. He sued under Section 2 of the Safety Appliance Act (SAA), which requires cars to have automatic couplers that couple by impact and can be uncoupled without people going between cars. At trial the judge directed a verdict for Hiles on liability, the Illinois Appellate Court affirmed, and the State Supreme Court denied review before the Justices took the case.

Reasoning

The Court considered whether a misaligned drawbar alone makes a railroad liable as a matter of law under §2. Relying on earlier SAA decisions, the Court explained that liability for equipment ‘‘failure to perform’’ assumes the coupler was properly placed to operate. A misaligned drawbar, the Court said, can result from ordinary railroad operations and is not necessarily a malfunction. The Court also noted the statute’s text, past enforcement structure, and Congress’ command only to require compatible automatic couplers — not devices that automatically realign drawbars — and therefore rejected reading §2 to impose automatic liability for misalignment.

Real world impact

The decision means injured workers who were harmed while straightening a misaligned drawbar cannot automatically win under §2; misalignment is not, by itself, a statutory violation. The ruling narrows the situations in which railroads face strict liability under the SAA and leaves room for other claims if supported by the record.