Minnesota Iron Co. v. Kline

Background

A worker lost an arm while repairing an engine on a narrow-gauge track that a mining company used to move dirt at its mine. The worker sued under a Minnesota law that makes railroad companies responsible for injuries caused by other employees, with a proviso about roads still under construction. A trial judge set aside the worker’s verdict as violating the Fourteenth Amendment, but the Minnesota Supreme Court reversed and entered judgment for the worker, and the case reached the United States Supreme Court.

Reasoning

The Court considered whether the state law, as the Minnesota court read it, was constitutional and whether it applied to the mining company’s track. The Court agreed with the state court’s reading. It said the proviso simply fixes the time when the law begins to operate—when a road is finished—rather than limiting the law to public travel. The Court held the legislature could treat the risks of rail work as a special category and could keep the old rule during construction for practical reasons. On that basis, the Court upheld the law and the worker’s recovery.

Real world impact

The ruling lets employees injured by coworkers on railroad operations recover under the Minnesota statute, including on industrial tracks used for mining. It affirms that a state can set special rules for risks faced by workers in particular industries and that such a law need not be struck down under the Fourteenth Amendment in this context.