Erie Railroad v. Hilt

Background

A boy less than seven years old was playing marbles on a railroad siding when his marble rolled under a railroad car. He reached for the marble and the car was backed, crushing his left leg so badly it had to be amputated. New Jersey law said anyone injured while walking, standing, or playing on a railroad could not recover damages from the railroad, except at a lawful crossing. A trial jury found for the boy and the Circuit Court of Appeals affirmed that verdict before the case reached the Supreme Court.

Reasoning

The question was whether the state law applied to very young children injured on railroad property. The Court read the statute literally and followed a prior New Jersey decision that applied the same rule to a younger child. The Court rejected the idea that "temptation" by railroad activity invited children onto the tracks. It explained that landowners need not protect trespassers from undisclosed dangers or stop lawful operations for people unlawfully on the premises.

Real world impact

The ruling prevents this injured child from recovering damages and enforces the state rule that people injured on railroad property while walking, standing, or playing generally cannot sue the railroad. The decision affects others who enter tracks unlawfully, including children, by limiting recoveries. It reverses the lower-court outcome and applies the state law as written.

Dissents or concurrances

Two Justices dissented, believing the statute should not apply to a child of seven and that the lower courts were correct to allow recovery.