Louisville & Nashville Railroad v. Melton

Background

Spencer Melton, a carpenter employed by a railroad construction crew, was injured on March 21, 1905, when a chain link holding a pulley broke and a heavy timber frame fell on him. Melton sued in Hopkins County, Kentucky, relying on an 1893 Indiana law that makes railroads liable for employee injuries caused by defective tools or negligent directions of a foreman. The railroad defended by pleading common‑law doctrines like coworkers bearing responsibility, contributory negligence, assumption of risk, and later argued the Indiana statute was unconstitutional under the U.S. Constitution’s equal protection guarantee.

Reasoning

The Supreme Court first found the railroad had not properly pressed a separate federal claim based on the full faith and credit clause, so that argument failed. On the key equal protection question, the Court explained that states have a wide, practical discretion to classify workers for safety and liability laws. It held the Indiana statute could validly include employees whose work is essential to railroad operation — such as bridge carpenters and coal‑tipple builders — and that treating those railroad workers differently from other jobs did not automatically violate equal protection. The Court therefore upheld the lower court’s application of the Indiana law to Melton’s circumstances.

Real world impact

The ruling lets injured railroad construction workers rely on Indiana’s employers’ liability law to recover for workplace injuries, even when common‑law defenses are asserted. It confirms legislatures can broadly classify workers for safety-related rules when the classification is practical and not plainly arbitrary.

Dissents or concurrances

Two members of the state court had dissented below, believing the statute as construed violated the federal equal protection guarantee; the Supreme Court nonetheless affirmed.