Norfolk Southern Railway Co. v. Sorrell
Headline: Railroad workplace injury rule: Court requires same causation standard for employer and employee under federal railroad liability law, forcing Missouri to change jury instructions and possibly trigger retrials.
Holding: The Court held that under FELA the same causation standard applies to railroad negligence and employee contributory negligence, vacating the Missouri judgment and remanding for further proceedings.
- Requires Missouri courts to use a single causation standard in FELA trials.
- May force retrials or new proceedings where older jury instructions misstated causation.
- Makes it clearer how juries apportion fault between workers and railroads.
Summary
Background
A railroad worker was injured on the job and sued his employer under the Federal Employers’ Liability Act (FELA). The Missouri trial used two different wording rules for cause: the railroad could be liable if its negligence contributed "in whole or in part," but the worker could be found contributorily negligent only if his negligence "directly contributed to cause" the injury. The trial judge overruled the railroad’s objection, a jury awarded $1.5 million, and the Missouri Court of Appeals affirmed.
Reasoning
The Supreme Court agreed to decide only whether FELA allows different causation standards for railroad and employee negligence. The Court relied on the long-standing common-law practice and on FELA’s text. Because FELA did not expressly change common-law rules about causation, and because the Act requires damages to be reduced "in proportion" to an employee’s fault, the Court found it sensible that both sides’ negligence be judged by the same causation test. The Court declined to resolve a larger, separate question about the precise content of the causation test (for example, differing readings of proximate cause) because that issue was not fully argued here.
Real world impact
The decision vacates the Missouri appellate ruling and sends the case back. Missouri must revise or reinterpret its approved jury instructions so both parties face a single causation standard. The state court must then decide if the instruction error was harmless or whether a new trial is needed. The ruling guides how FELA trials should be instructed going forward.
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