Boldt v. Pennsylvania Railroad

Background

A railroad company that operates a freight yard in Buffalo, New York, faced a suit after Edward J. Boldt, an experienced yard conductor, was killed while between freight cars adjusting a faulty coupler. The yard used a “hump” system where cuts of cars were sent down by gravity and often bumped other cars to couple. Company rules forbade going between cars without precautions, but evidence showed a long-standing practice of sending cars to strike others, and the decedent was working contrary to instructions when the accident occurred. The worker’s representative sued under the Federal Employers’ Liability Act, claiming the moving cars struck with excessive force and that the railroad failed to make or enforce adequate safety rules.

Reasoning

The core question was whether the court should tell the jury that, under the Employers’ Liability Act, an employee does not assume risks caused by the carrier’s officers, agents, or employees. The trial judge had already instructed the jury that the decedent assumed the ordinary risks of his job and refused the specific instruction the plaintiff requested. The Court held the requested instruction misstated the law. It explained that the Act preserves the doctrine that employees assume extraordinary and obvious risks, while only eliminating the assumption-of-risk defense in the special situations listed in §4 of the statute, such as violations of safety statutes.

Real world impact

The decision affirms the lower-court judgment and makes clear that employees continue to bear ordinary job risks under the Act. Only in the limited cases described by the statute—for example, where a safety law violation contributed to injury—will assumption-of-risk be removed as a defense.