Seaboard Air Line Railway v. Tilghman

Background

A train conductor was hurt in a head-on collision between two passenger trains. He sued under the federal Employers’ Liability Act. At trial a jury found both the railway company and the conductor were at fault, and awarded $7,000. The state trial court entered judgment for that amount and the state supreme court affirmed, with two judges dissenting.

Reasoning

The Court addressed whether the trial court properly followed the part of the federal law that tells juries how to reduce damages when a worker’s negligence partly caused the injury. At common law, an employee could not recover if he was even partly at fault. The statute changed that by allowing recovery but requiring the jury to diminish damages in proportion to the amount of negligence attributable to the employee. Instead of applying that proportional rule, the trial judge told jurors to deduct whatever amount they thought reasonable for the employee’s fault. The Court said that instruction failed to give proper effect to the statute’s proportional rule and that the jury should have been told to measure the deduction by the employee’s share of the total causal negligence.

Real world impact

The decision requires courts to instruct juries to calculate reduced awards by proportion, not by vague notions of reasonableness, when workers share fault under the federal act. That can change recoveries in workplace and railroad injury cases and affects how juries apportion blame between employers and injured workers.

Dissents or concurrances

The state supreme court’s decision had two dissenting judges who did not agree with the affirmation of the judgment.