Shanks v. Delaware, Lackawanna & Western Railroad

Background

Shanks, a railroad worker, was injured in New Jersey while moving an overhead counter-shaft in his employer's machine shop. He sued the railroad under the federal Employers' Liability Act in New York state court. A jury found for Shanks, but New York appellate courts reversed, concluding he was not employed in interstate commerce when hurt. Shanks brought the case to the Supreme Court for review.

Reasoning

The main question was whether Shanks's task made him an employee "in interstate commerce" under the Act. The Court explained that the Act applies when an employee is engaged in interstate transportation or in work so closely related that it is practically a part of that transportation. The opinion reviewed prior cases that applied or denied federal coverage based on how directly the work supported movement of interstate trains. Because Shanks was altering the location of a heavy shop fixture that merely supplied power to repair machines, his work was too remote from interstate transportation to qualify. The Court therefore held he was not covered by the federal Act and affirmed the judgment against him.

Real world impact

This decision narrows when injured railroad workers can sue under the federal Employers' Liability Act. Workers doing maintenance or shop alterations not directly tied to moving interstate trains will generally need to seek damages under state law. The ruling draws a practical line between shop work that is part of interstate transportation and repair or relocation work that is not.