Schlemmer v. Buffalo, Rochester & Pittsburg Railway Co.

1907-03-04

Headline: Worker killed while coupling an interstate shovel car: Court reversed state judgment, ruled federal coupler law prevents treating employee as having assumed the risk when cars lack required automatic couplers, protecting railroad workers' claims.

Holding:

Real World Impact:

Protects railroad workers from being held to have assumed risk when cars lack required couplers.
Makes it harder for employers to avoid liability by claiming worker assumed the risk.
Limits state courts from sidestepping federal safety statutes by recharacterizing claims.

Topics: workplace safety, railroad safety, federal safety law, employee injuries

Summary

Background

A widow sued after her husband, Adam M. Schlemmer, was killed while trying to couple a steam-shovel car to a caboose. The shovel car was being moved from Limestone, New York, through Pennsylvania and did not have the automatic coupler required by federal law. The car had a heavy iron drawbar with an eye that a worker had to guide into a small slot while crouching beneath the car at dusk. Schlemmer was warned twice to keep his head down, rose a little too high, missed the slot, and his head was crushed.

Reasoning

The key question was whether the federal statute that forbids using cars without required automatic couplers also prevents treating an injured employee as having “assumed the risk.” The Pennsylvania trial court directed a nonsuit for contributory negligence and the state supreme court affirmed. The U.S. Supreme Court, speaking through Justice Holmes, held that the federal law protects an employee from being treated as assuming that risk and that the state courts had wrongly let that protection be swallowed up by labeling the same facts as contributory negligence. The Court found the state rulings entangled with errors about the federal statute and reversed the judgment.

Real world impact

The decision means employees who are hurt while working with cars that violate the federal coupler law cannot be denied recovery simply by calling their conduct negligent when the risk arises from the illegal equipment. The ruling enforces the federal safety statute against efforts to avoid it by recharacterizing the claim in state court.

Dissents or concurrances

Justice Brewer (with three colleagues) dissented, arguing the evidence supported a factual finding of contributory negligence and that the statute did not eliminate the ordinary defense of contributory negligence in this case.