Spokane & Inland Empire Railroad v. Campbell

Background

A motorman on an electric single-track line running between Spokane and Coeur d’Alene was driving a special passenger motor car when he collided with a regular eastbound train and suffered serious injuries. He said he had written and verbal orders to meet the other train at a station called Alan; the conductor disputed the exact wording. The jury found the motorman left his station in violation of the orders but also found his train’s air brakes were insufficient just before the collision.

Reasoning

The Court considered whether the employer could be held responsible under two federal laws: the Safety Appliance Act (which requires effective train brakes) and the Federal Employers’ Liability Act (which allows injured employees to recover for employer negligence). The Court held that the Safety Appliance Act applies to electric interurban trains and that defective brakes are negligence regardless of who caused the defect. It also held that an employee’s mistaken or negligent act in following orders does not automatically remove him from the scope of employment. Because the jury found defective brakes contributed to the crash, the employee’s recovery could not be defeated by his error.

Real world impact

The decision affirms that railroad companies must keep braking equipment in proper working order, including electric motor trains, and that employees injured when defective safety equipment contributes to an accident can recover even if they made mistakes. The ruling enforces federal safety standards for train equipment and confirms employee protection under the liability law.