Baltimore & Ohio Railroad v. Wilson

Background

A freight conductor sued his railroad for serious injuries, saying he had been kept on duty for more than sixteen hours and then, about fourteen hours later, put back to work and hurt because he was exhausted. He was trying to cut a car with a hot box from a train, stood on the running board at the rear of an engine on a side track, stepped off when the engine drifted past the car on the main track, and was badly injured. The case was tried under the Hours of Service Act (1907) and the Employers’ Liability Act (1908).

Reasoning

The Railroad argued the conductor was not kept on duty more than sixteen hours, but the jury found otherwise. The Railroad also said any injury must occur during the actual statutory violation, or that the law’s requirement of ten hours off after sixteen hours limits any connection between overwork and later injury. The Court rejected those narrow limits. It explained that evidence showed the conductor had been greatly overtaxed and that fatigue could have been a proximate cause of the accident, even if the statutory violation had ended earlier. Under the Employers’ Liability Act provisions discussed, proof that the employer violated a safety statute that proximately contributed to injury removes the usual defenses of contributory negligence and assumption of risk.

Real world impact

The ruling allows workers to recover when dangerous overwork contributes to injury even if the breach ended before the accident, so employers face liability when excessive duty leads to disabling fatigue. The decision leaves open that final outcomes depend on trial evidence about fatigue and causation.