CSX Transportation, Inc. v. McBride
The Supreme Court ruled that a federal law letting railroad workers sue their employers for injuries does not require proof of the strict common-law 'proximate cause' standard used in ordinary negligence suits. Instead, a jury only needs to find that the railroad's negligence played some part, however small, in causing the injury.
The decision upholds the jury instruction used in a locomotive engineer's hand-injury case against CSX and confirms an approach nearly every federal appeals court had already been using, making it harder for railroads to escape liability by arguing their negligence was too indirect a cause.
How it got here: A jury found for McBride after the trial court refused CSX's requested "proximate cause" instruction; the Seventh Circuit affirmed, and CSX asked the Supreme Court to review the causation standard.
The Case in Depth
What happened
Robert McBride, a locomotive engineer for CSX Transportation, was assigned to a train with an unusual mix of large and small engines that required constant use of a hand brake during a long shift of stopping and starting to move rail cars. He objected that the setup was unsafe but was told to proceed anyway, and about ten hours into the run he injured his hand using the brake, permanently losing full use of it. He sued CSX under the Federal Employers' Liability Act, arguing the railroad was negligent in requiring unsafe equipment and failing to train him properly.
The question before the Court
Could a railroad worker win his on-the-job injury lawsuit by showing his employer's negligence played any part in causing the injury, without proving the stricter common-law test of "proximate cause"?
Why it matters
Railroad workers injured on the job will find it easier to win damages, because they need only show their employer's carelessness contributed in some part to their injury rather than meeting a stricter legal-causation test. Railroads, in turn, face a somewhat broader scope of potential liability in the roughly 100-year-old federal law covering on-the-job injuries.
What changes now
This is a final merits decision that resolves the causation standard under the Federal Employers' Liability Act nationwide, aligning the law with what nearly all federal appeals courts were already doing. The judgment for McBride stands, and CSX must pay the reduced damages the jury awarded. Going forward, trial courts in FELA cases should continue using instructions asking only whether the railroad's negligence played any part in the injury, without additional 'proximate cause' language.
What this does not decide
The Court did not decide that FELA imposes unlimited liability; it emphasized that ordinary negligence still requires foreseeable risk of harm, and that FELA's own limits—covering only employees injured during their jobs—keep liability from covering far-fetched or unrelated harms, even without a separate proximate-cause instruction.
Concurrences and dissents
Concurrence in part — Justice Thomas
Justice Thomas joined the Court's opinion in full except for Part III-A, which discussed at length the history and confusing variety of common-law formulations of 'proximate cause.' He did not explain his reasons for declining to join that portion.
Dissent — Justice Roberts
Chief Justice Roberts argued that FELA generally incorporates common-law negligence principles unless Congress said otherwise, and Congress only expressly abolished four specific common-law defenses, not proximate cause. He read Rogers as addressing only how multiple causes (like employee versus employer fault) are weighed, not whether a direct causal link is required, and warned that the majority's 'any part' test is really unlimited 'but for' causation with no real boundary on liability.
How the Court got there
The legal reasoning, step by step
- The Court examined the text of the Federal Employers' Liability Act, which makes railroads liable for worker injuries 'resulting in whole or in part' from the railroad's negligence, and found this language broader than ordinary negligence law's proximate-cause requirement.
- The Court read its 1957 decision in Rogers v. Missouri Pacific R. Co. as having already established that a FELA jury need only find that the railroad's negligence played any part, even the slightest, in causing the injury, rejecting the railroad's argument that Rogers addressed only cases with multiple contributing causes.
- The Court traced this reading through decades of its own later cases and the pattern jury instructions used by nearly every federal appeals court, concluding that the 'any part' standard has been the settled, uniform understanding of FELA causation for over fifty years.
- The Court reasoned that 'proximate cause' is itself a vague, inconsistently defined legal label rather than an essential legal requirement, and that Congress's simple statutory phrase was meant to avoid exactly this kind of confusing common-law terminology.
- The Court concluded that ordinary negligence law's foreseeability requirement, plus FELA's built-in limits (only employees, only injuries during employment), keep liability from becoming limitless even without a separate proximate-cause instruction.
- Applying this framework, the Court held that the trial court's instruction—telling the jury CSX 'caused or contributed to' McBride's injury if its negligence 'played a part—no matter how small' in bringing it about—correctly stated the law.
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 establishing a relaxed, 'any part' causation standard for all FELA cases.