Kinzell v. Chicago, Milwaukee & St. Paul Railway Co.

Background

A railroad company was filling a long wooden trestle with earth so the track could be carried on a solid embankment. The track across the trestle was in daily interstate use. A railroad employee, Kinzell, operated a flat-car dozer and used a shovel to clear earth from the rails and push fill outward. He was injured while coupling cars to the dozer during this work. The state supreme court held the work was "new construction" and not part of interstate commerce, denying recovery.

Reasoning

The central question was whether Kinzell’s work counted as employment in interstate commerce under the Federal Employers’ Liability Act. The Court examined whether the tasks were closely connected to the railroad’s interstate operations or merely independent construction. It found the dozer and shovel were used directly to keep the rails clear for trains and to widen the embankment so interstate trains could run safely. Because his duties immediately furthered interstate train operations, the Court concluded his employment was part of interstate commerce.

Real world impact

The Supreme Court reversed the Idaho decision and sent the case back for further proceedings consistent with this ruling. The practical effect is that workers doing similar track-clearing or safety tasks during bridge filling are treated as engaged in interstate commerce for purposes of the federal employers’ liability law. The case returns to the lower court for further steps consistent with that legal ruling.