Raymond v. Chicago, Milwaukee & St. Paul Railway Co.
Headline: Court affirmed dismissal of an injured railroad worker’s federal negligence suit, holding FELA did not apply to work on an unfinished tunnel and state workers’ compensation law governs recovery.
Holding: The Court held that, on the facts alleged, the railroad and worker were not engaged in interstate commerce so the federal employers’ liability law did not apply, and Washington’s workers’ compensation law instead bars a common-law suit.
- Bars federal FELA claims when workers are on unfinished, non-operational interstate structures.
- Requires injured railroad laborers in similar situations to seek recovery under state workers’ compensation.
- Affirms that general interstate business does not prevent state workers’ compensation from applying.
Summary
Background
A laborer named Raymond sued a railroad company after a pick he used struck a charge of dynamite left in a tunnel being cut through a Washington mountain. Raymond alleged he was injured by the explosion while working for the railroad, which was shortening its main line between Chicago and Seattle. The railroad denied the federal claim, saying the tunnel was not yet in use for interstate commerce, and it said Washington’s workers’ compensation law applied because the company had complied with that law.
Reasoning
The key question was whether the federal employers’ liability law applied, or whether state law controlled. The Court said that, on the facts alleged, the tunnel work was not an active part of interstate commerce and therefore the federal law did not provide a claim. The Court also explained that if the complaint were treated as a common-law negligence case, the state workers’ compensation law—held constitutional in a companion decision that day—would prevent a common-law recovery. The Court noted that merely being generally engaged in interstate business did not stop the state compensation law from operating.
Real world impact
The decision affirms the lower court’s dismissal and means similar injured workers at unfinished or nonoperational sites must rely on state workers’ compensation systems rather than the federal employers’ liability law. Employers who follow state compensation rules can avoid common-law negligence suits in these circumstances.
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