New Orleans & Northeastern Railroad v. Scarlet

Background

Scarlet, a fireman for the New Orleans & Northeastern Railroad, was injured when he was thrown down between the locomotive and its tender after the engine and tender uncoupled. The uncoupling followed the breaking of the king pin and the coupling chains. Scarlet sued in Mississippi under the federal Employers’ Liability Act and the Boiler Inspection Act. A state trial court instructed the jury that Mississippi’s 'Prima Facie Act' relieved him of proving negligence; the jury returned a verdict for Scarlet and the Mississippi Supreme Court affirmed.

Reasoning

The Railroad argued the state instruction conflicted with federal law. Scarlet conceded that the state statute could not constitutionally be applied to claims under the federal employers’ liability law, relying on an earlier decision, and the Court considered whether the Railroad was prejudiced by the error. Scarlet also argued that the Boiler Inspection Act imposed an absolute duty so that the mere breaking of parts proved defect as a matter of law. The Court concluded the evidence did not establish as a matter of law that the king pin or chains were defective; that factual question belonged to the jury. Because the incorrect state-law instruction could have affected the outcome, the Court reversed the judgment.

Real world impact

The ruling confirms that juries must decide whether equipment failures reflect defects rather than allowing a state rule to remove an injured worker’s burden of proof in federal employer-liability cases. It also affirms that state statutes cannot override federal proof requirements in such claims. The case was reviewed here because a state statute conflicted with federal law, and the Court denied the petition for a separate review (certiorari).