Chesapeake & Ohio Railway Co. v. Carnahan

Background

A railroad company was sued under the Employers’ Liability Act by a fireman who was badly injured when two trains collided. The fireman was pinned between the tender tank and the boiler head for forty-five to fifty minutes, and his leg was so badly mashed and burned that it later had to be amputated between the knee and the thigh. The injury happened while he was engaged in interstate train service. The case was tried under state procedure to a jury of seven, and the jury awarded the fireman $25,000. The railroad appealed, arguing among other things that the Constitution required a twelve-person jury.

Reasoning

The Court addressed two main questions: whether federal law demands a twelve-member jury in these cases, and whether the trial court’s damages instruction was improper. The Court rejected the railroad’s jury-size claim, citing a same-day decision and holding that the seven-member jury was permissible. The Court also upheld the damages instruction, saying it did not improperly invite speculation and that the jury could consider future effects of the injury when supported by the evidence. The Court emphasized that the trial court separately instructed the jury that any award must be the direct and proximate result of the company’s negligence.

Real world impact

The result means the $25,000 verdict stands. It confirms that state procedures that provide smaller juries can be used in Employers’ Liability Act trials, and that juries may include foreseeable future physical effects in damage awards when evidence supports them. The decision relies on earlier cases that allow recovery for future consequences when they are shown by the record.