Chicago, Burlington & Quincy Railroad v. Harrington

Background

Margaret Harrington sued to recover damages after her husband, Patrick Harrington, a switchman for a railroad company, was killed while working in the company’s Kansas City terminal yards. The yards handled both interstate and intrastate traffic. The switching crew worked only inside the State and was moving company-owned coal from a storage track into a coal shed or chutes. The coal had been in storage for a week or more before the accident. The state court entered judgment for the widow under state wrongful-death law. The railroad argued the work was part of interstate commerce and that the Federal Employers’ Liability Act therefore governed.

Reasoning

The Court addressed whether the switchman’s task was part of interstate commerce or so closely related that the Federal Act applied. The Court used the practical test from earlier cases: was the employee at the time of injury engaged in interstate transportation or in work practically a part of it? The Court found no close or direct relation to interstate transportation in moving stored coal into chutes. That task simply positioned fuel for later use and was not the kind of activity covered by the federal law, and prior decisions treating similar coal work as outside the Act supported that view. The Court affirmed the state-court judgment.

Real world impact

As a result, the widow keeps her state-law remedy because her husband’s work was not deemed interstate commerce. The decision narrows the Federal Employers’ Liability Act to duties directly and closely tied to interstate transport. Rail employees who perform internal yard or supply tasks like moving stored coal will not automatically be covered by the federal statute, and similar claims may proceed under state law.