Baltimore & Ohio Southwestern Railway Co. v. Voigt

1900-02-26

Headline: Court upheld an express messenger’s written release, allowing a railroad to avoid liability for his injuries and making it easier for carriers and employers to require such waivers.

Holding: An express messenger who voluntarily signed a release agreeing the railroad would not be liable cannot avoid that agreement, and the railroad is not responsible for his injuries under those contract terms.

Real World Impact:

Allows carriers and express companies to require messengers to sign liability releases.
Limits recovery by employees who freely accept contracts releasing carriers from claims.
Treats express-car arrangements more like employment than ordinary passenger transport.

Topics: railroad liability, express messengers, contracts and waivers, workplace injuries

Summary

Background

William Voigt was an express messenger employed under a long-term arrangement between an express company and a railroad. The railroad agreed to provide cars and transport express shipments; the express company agreed to protect the railroad from liability. Voigt signed a written agreement indemnifying the express company and releasing the railroad from claims. While riding in an express car on December 30, 1895, he was injured in a collision with another train owned by the railroad and sued for damages.

Reasoning

The Court asked whether Voigt could avoid the release by invoking public policy that usually prevents carriers from contracting away responsibility for passenger injuries. The majority said no. It emphasized that Voigt was riding as part of his regular employment under a special contract between companies, not as an ordinary passenger demanding transportation. Because the express arrangement resembled an employment or private-carriage relationship and was entered into freely, the Court found the release valid and enforceable under the facts presented.

Real world impact

The decision means that employees or messengers who voluntarily accept jobs that require signed releases may be bound by those contracts and may not recover from the railroad for injuries covered by the release. The ruling rests on the specifics of contracts made between express companies and railroads and does not overturn the broader rule that ordinary passengers cannot be required to waive liability for carrier negligence.

Dissents or concurrances

Justice Harlan dissented, arguing the case fell within older decisions that forbid carriers from exempting themselves from negligence liability, and he would have allowed recovery regardless of the technical employment label.