New Orleans & Northeastern Railroad v. Harris

Background

Van Harris was a brakeman working in interstate commerce for a railroad and was run over by the tender of an engine in New Orleans on February 5, 1914, dying within minutes. His mother qualified as administratrix and sued in a Mississippi state court under the Federal Employers’ Liability Act, claiming the railroad’s negligence. The declaration did not allege any conscious pain or suffering. Evidence about the accident and the decedent’s family situation was mixed; he had married a woman named Mollie who was alive at trial, and no children were shown. The trial judge instructed the jury using a Mississippi statute that treated proof of injury by an engine as prima facie evidence of negligence and shifted the burden to the railroad.

Reasoning

The central question was whether a state rule that presumes negligence could alter proof requirements in a federal employer-liability case. The Court held that negligence is an affirmative fact the claimant must prove in such federal actions, and the burden of proof is substantive and governed by federal law rather than state statutes. It also explained that because no conscious suffering was alleged and a widow survived, the mother could not recover for pecuniary loss under the statute’s beneficiary rules. The trial court erred in giving the prima facie instructions and in allowing certain damages to be considered without proper proof.

Real world impact

The Court reversed the state-court judgment and sent the case back for further proceedings consistent with this opinion. Going forward, employees suing under the federal act must prove negligence, state presumptions cannot shift that burden in these federal suits, and recoveries depend on proved beneficiaries and types of loss shown.