Mobile, Jackson & Kansas City Railroad v. Turnipseed

Background

A railroad worker, Ray Hicks, was killed when a derailed car fell on him while he worked as a section foreman repairing track. His family sued the railroad for wrongful death in Mississippi state court. The state trial court entered judgment for the family, and the Mississippi Supreme Court affirmed. The railroad challenged two Mississippi laws under the Fourteenth Amendment’s equal protection guarantee: one law (section 3559) removes the old fellow‑servant defense for railroad employees, and the other (section 1985) says proof that a person was injured by the running of locomotives or cars is prima facie evidence (an initial presumption) of lack of reasonable care by the railroad’s servants.

Reasoning

The Court asked whether those laws unconstitutionally singled out railroad companies or denied due process. It held that treating railroad employees as a special class is reasonable because many railroad roles expose workers to hazards from trains, and Hicks’s work put him plainly within that hazard. As to the evidence rule, the Court explained the statute creates a rebuttable presumption—proof of an injury from running trains shifts the burden to the railroad to offer contrary evidence. The rule applies only to passengers and employees and to injuries from train operation. Because the presumption rests on a rational connection between derailments and possible negligence, and does not prevent the railroad from presenting a defense, it does not violate equal protection or due process.

Real world impact

The decision lets injured railroad employees and passengers rely on a legal inference of negligence in train‑operation accidents, making it easier to win damages unless the railroad rebuts the presumption. The judgment for Hicks’s family was affirmed.