CSX Transportation, Inc. v. McBride

Background

Robert McBride, a locomotive engineer, injured his hand in 2004 while using a hand-operated independent brake on a train CSX assigned him. McBride sued CSX under the Federal Employers’ Liability Act (FELA), claiming unsafe equipment and insufficient training. At trial the judge told jurors they could find CSX liable if its negligence caused or contributed to the injury; CSX sought a traditional proximate-cause instruction but the court refused. A jury awarded McBride damages and the Seventh Circuit affirmed.

Reasoning

The Court considered what causation standard FELA requires. Reading FELA’s wording that injuries are those "resulting in whole or in part" from carrier negligence and following its earlier Rogers decision, the majority held that FELA does not import restrictive common-law proximate-cause tests. Instead, juries may be instructed that a railroad caused or contributed to an injury if the railroad’s negligence played any part, even the slightest, in bringing about the harm. The Court stressed long-standing federal practice adopting that "any part" formulation and said foreseeability remains part of proving negligence, not an extra barrier to recovery.

Real world impact

Practically, the ruling lowers the causation threshold for railroad employees suing under FELA: employees can get a jury decision when employer negligence contributed in any degree. Railroads face a wider path to liability in workplace-injury suits, while juries are still to apply ordinary negligence proof and common sense. The Court affirmed the Seventh Circuit’s judgment and left to Congress any change in the rule.

Dissents or concurrances

Chief Justice Roberts, joined by three Justices, dissented, arguing FELA should retain traditional proximate-cause limits and warning the majority’s rule collapses into broad but-for liability without proper legal limits.