Kansas City Southern Railway Co. v. Jones

Background

A woman sued a railroad in state court after her husband, an engineer on a passenger train, was killed when a loaded car ran down a grade and struck his engine. She brought the case under the Federal Employers’ Liability Act seeking damages as his administrator. A jury found for her and the state courts affirmed. At trial the railroad tried to question a witness about whether the engineer failed to keep the train under proper control, but the trial judge excluded all evidence of the engineer’s fault because contributory negligence was not pleaded.

Reasoning

The central question was whether the railroad had a federal right under the Act to offer evidence that the worker was partly at fault so a jury could reduce damages. The Court pointed to the Act’s provision that an employee’s fault does not bar recovery but requires damages to be reduced in proportion to the employee’s share of negligence. That rule gives carriers a federal right to present mitigation evidence. Because the trial court excluded all such evidence, the Court held the railroad was improperly deprived of its federal right and reversed the judgment.

Real world impact

Going forward, trials under the Federal Employers’ Liability Act must allow carriers to introduce evidence that an employee was partly responsible so juries can lower awards accordingly. State trial judges may not categorically bar mitigation evidence simply because contributory negligence was not pleaded. The case is procedural and returns to the state court for further proceedings consistent with the federal law, so final damages could still change.