Louisville & Nashville Railroad v. Stewart

Background

A widow sued a railroad under the Employers’ Liability Act of 1908 after her husband, an engineer named Stewart, died when he struck his head during a sudden stop. The case went to trial twice: the first jury verdict for the widow was set aside by the state Court of Appeals, and a second trial produced a smaller judgment that was sustained. The railroad sought review of that second judgment, and the widow asked to reinstate the first verdict; the Supreme Court would not reinstate the first verdict because the original jury had been given an improper instruction.

Reasoning

The Court addressed whether the railroad and its employees could be held responsible for the death caused when a brakeman suddenly applied the airbrakes while the train was backing. The Court found evidence that the brakeman’s sudden action could be a breach of duty and the kind of act likely to cause the kind of injury that occurred, and that the jury could reasonably find the conductor or other employees negligent. The Court also rejected the railroad’s procedural objections: a state rule allowing interest or a ten-percent cost for a supersedeas was permissible, and the railroad’s argument about local jury rules was answered by earlier precedent. The Court concluded the trial instructions were not wrong as a matter of federal law and affirmed the judgment.

Real world impact

The ruling lets a jury decision stand that a railroad can be liable for sudden, dangerous acts by its crew that cause employee deaths, while recognizing a State may set costs or interest rules for appeals. The first trial’s verdict could not be reinstated because of an improper instruction, so the affirmed second judgment remains the operative result.