Minneapolis & St. Louis Railroad v. Bombolis

Background

A representative of a worker who died (Nanos) sued a company under the federal Employers’ Liability Act, saying the company’s negligence caused the death while the worker was in interstate commerce. The case was tried in a Minnesota state court. Minnesota law lets a jury return a verdict with five‑sixths agreement after twelve hours without unanimity. At trial the company objected, saying the federal Constitution’s right to a jury required a unanimous verdict, but the state court overruled the objection and entered judgment for the worker’s representative.

Reasoning

The main question was whether the Seventh Amendment’s guarantee of a common‑law style jury (which requires unanimity in federal courts) applies to trials held in state courts enforcing federal statutory rights. The Court explained that the first ten Amendments, including the Seventh, restrict only federal government action and apply to proceedings in United States courts. State courts are governed by state law for their procedures. Because Congress allowed federal rights to be enforced in both federal and state courts, applying a state procedural rule like the five‑sixths verdict does not violate the Seventh Amendment. The Court therefore affirmed the state court’s use of the state rule.

Real world impact

Federal statutory claims tried in state court will be decided under the state’s trial procedures, including rules about jury unanimity. People and companies defending federal claims in state court cannot force federal unanimous‑jury procedures; state procedures control. This decision restates a long‑standing rule that the Bill of Rights’ jury guarantee governs federal, not state, court procedures.