Louisville & Jeffersonville Bridge Co. v. United States

Background

A terminal railroad company operating a large yard in Louisville assembled twenty-six coupled cars and moved them as a unit from one terminal to another without connecting the train brakes. The movement covered long distances inside the yard and on main-line tracks, crossed several city streets at grade (one crossing reached 15 miles per hour), and involved starts and stops while other engines and trains used adjacent tracks. The carrier argued this was only a short “switching” operation and therefore not subject to the Safety Appliance Act’s 85 percent brake requirement.

Reasoning

The Court addressed whether the Safety Appliance Act and the Interstate Commerce Commission’s 85 percent rule apply to the described transfer. The justices concluded that an engine and twenty-six coupled cars constitute a train and that the described transfer — a long movement as a unit across busy yards, main tracks, and street crossings — is a train movement within the statute’s meaning. The Court emphasized the practical need for engineer control of train brakes to protect employees and the public, rejected the carrier’s alternative-safety arguments, and relied on earlier decisions that require strict compliance where the law applies.

Real world impact

The decision requires rail carriers to couple and enable train brakes on at least 85 percent of cars in similar long transfers that run over main tracks or cross public streets, rather than treating them as exempt switching moves. It makes clear carriers cannot avoid the statutory brake requirement by pointing to other protections or gatekeepers; engineers must be given control sufficient to stop the train promptly.