Myers v. Pittsburgh Coal Co.

Background

Annie Myers, the widow of John Myers, sued a coal company after her husband, a 29-year-old miner who worked as a brakeman riding the rear of empty coal cars, was found mangled on the tracks and shortly died. On the morning of the accident the motor car that moved empty cars was running without an effective headlight, and an overhead live trolley wire crossed the track about 5 feet 7½ inches above the rail with no guard. John Myers signaled the motor car with a cap lantern; his cap was found beside the track with the light still burning. A jury found for the widow, but the federal appeals court reversed without ordering a new trial.

Reasoning

The Court considered whether the evidence was strong enough for a jury to decide that the company’s failure to keep the work area safe caused the death. The opinion explains that reasonable jurors could find it likely Myers touched the low live wire, was thrown or stunned, and then was run over because the motor car lacked a working headlight and the entry had inadequate lighting. The Court also noted testimony that the company’s electrical superintendent—not the mine foreman—was in charge of the electrical system, making the company responsible for maintenance. Because the appeals court set aside the verdict for lack of evidence, the Supreme Court reversed that reversal and let the jury’s verdict stand.

Real world impact

This decision reinforces that juries may decide negligence cases when facts reasonably support a causal story. Mine operators and other employers must keep lighting and electrical equipment in safe condition and guard live wires. The case was sent back to the trial court (the District Court) for further proceedings to implement the jury’s award.