CSX Transportation, Inc. v. McBride
The Court ruled that railroad workers suing their employers for on-the-job injuries under a federal law called FELA don't have to meet the traditional common-law test for 'proximate cause.' Instead, juries can find for the worker if the railroad's negligence played any part, however small, in causing the injury.
The decision preserves a jury instruction that federal appeals courts have used for decades, rejecting the railroad's push to import stricter tort-law causation rules into these cases and reaffirming a worker-friendly reading of the statute.
“Under [FELA] the test of a jury case is simply whether the proofs justify with reason the conclusion that employer negligence played any part, even the slightest, in producing the injury or death for which damages are sought.”
The Court's core statement of the relaxed causation standard for FELA cases.
How it got here: A federal trial court ruled for the injured worker using a relaxed causation jury instruction; the Seventh Circuit affirmed, and the railroad asked the Supreme Court to review that instruction.
The Case in Depth
What happened
Robert McBride, a locomotive engineer for CSX Transportation, injured his hand while operating a hand-brake on an unusually configured train during a switching run. He sued CSX under FELA, claiming the railroad made him use unsafe equipment and failed to train him properly. CSX argued that even if negligent, its conduct wasn't a close enough cause of McBride's injury to trigger liability.
The question before the Court
When a railroad worker sues his employer for a job injury, must he prove the old-fashioned "proximate cause" standard, or something looser?
Why it matters
Injured railroad workers bringing FELA lawsuits will keep benefiting from a lenient causation standard that makes it easier to get a case to a jury and win damages, since they need only show the railroad's negligence played any part in the injury. Railroads, meanwhile, remain unable to insist on stricter proximate-cause instructions that might have limited their liability.
What changes now
This is a final merits decision resolving the causation standard for FELA suits nationwide; there is no remand because the Seventh Circuit's judgment for McBride is affirmed outright. Lower courts will continue using the 'any part, no matter how small' jury instruction in FELA cases, and railroads can no longer argue that traditional common-law proximate-cause language must be given instead.
What this does not decide
The Court did not decide that FELA imposes truly limitless liability; it stressed that juries must still find the railroad negligent in the first place, using ordinary foreseeability principles, and that common sense would prevent absurd 'but for' verdicts. It also did not adopt any single verbal formula beyond approving the Rogers-based instruction.
Concurrences and dissents
Concurrence in part — Justice Thomas
Justice Thomas joined the Court's opinion in full except for Part III-A, agreeing with the outcome and the core holding on causation but not joining the section that critiqued the concept of 'proximate cause' as a term and explored its history and confusing formulations.
Dissent — Justice Roberts
Chief Justice Roberts argued that FELA's text and decades of pre-Rogers precedent required plaintiffs to prove ordinary proximate cause, and that FELA only abolished specific common-law doctrines like contributory negligence, not proximate cause generally. He contended the Rogers 'any part' language addressed apportioning fault between employer and employee, not the directness of causation, and warned that the majority's test amounts to limitless 'but for' liability with no real boundary.
How the Court got there
The legal reasoning, step by step
- The Court examined FELA's text, which makes railroads liable for injuries 'resulting in whole or in part' from their negligence, and treated this broad phrasing as Congress's own definition of how directly a railroad's negligence must relate to an injury.
- Relying on its 1957 decision in Rogers v. Missouri Pacific R. Co., the Court read that case as establishing a comprehensive, relaxed causation standard for FELA cases -- not a narrow rule limited to situations involving multiple contributing causes or comparative fault.
- The Court gave weight to the fact that every federal court of appeals reviewing FELA cases, along with the vast majority of state courts and legal scholars, had for over fifty years understood Rogers the same way, treating that shared understanding as settled law entitled to added weight under the doctrine of stare decisis (the practice of following prior decisions).
- The Court reasoned that requiring 'reasonable foreseeability' as part of proving negligence in the first place -- rather than as a separate, stricter causation test -- adequately guards against runaway liability, especially combined with FELA's built-in limits on who can sue and for what kinds of harm.
- Applying this framework, the Court concluded that an instruction telling the jury the railroad's negligence must have 'played a part -- no matter how small' in causing the injury was legally correct and did not need to include traditional proximate-cause language.
Doctrinal impact
Cases affected by this decision
Reaffirms Rogers v. Missouri Pacific R. Co. (352 U. S. 500)
The Court reaffirmed and clarified Rogers as stating the comprehensive causation test for all FELA cases, not just multi-cause ones.