Atlantic Coast Line Railroad v. Burnette

Background

A fireman employed by a railroad was hurt on October 5, 1907 while working on a train running between South Carolina and North Carolina. He sued on January 7, 1910, and the State Supreme Court entered judgment in his favor after treating the federal Employers’ Liability Act of April 22, 1908 as governing the case. Two objections were later raised: whether that federal law applied, and whether the suit was filed too late under the law’s two-year limit.

Reasoning

The Court focused on the practical question of whether the 1908 federal law created the only enforceable obligation and, if so, whether its two-year time limit barred this late suit. The record showed that the railroad had argued at trial the Act didn’t apply, and the Court noted authorities indicating the Act might not cover this case. The Court also found the action was brought more than two years after the injury. Because a federal statute that creates a right and also sets a time limit must be respected, the Court concluded the judgment that proceeded under the 1908 Act could not stand.

Real world impact

The decision reverses the state-court recovery insofar as it rested on the federal Act and underscores that state courts must respect federal time limits for claims created by federal law. For railroad employees and carriers, suits filed after the federal two-year period may be barred even if the claim was decided differently in a state court.