Chicago, Rock Island & Pacific Railway Co. v. Cole

Background

A woman sued a railroad company after her relative, Roberts, stepped onto a track and was killed while a train approached in full view. The state trial jury returned a verdict for the woman. Oklahoma’s Constitution contains a rule that the defense of contributory negligence or assumption of risk must be left to the jury as a question of fact. The Oklahoma Supreme Court applied that constitutional rule, upheld the jury’s verdict, and held the rule did not violate the federal Constitution.

Reasoning

The United States Supreme Court asked whether Oklahoma’s rule—making negligence defenses a jury question—violated the Fourteenth Amendment. The Court said a State may allocate roles between judge and jury differently from common law practice. The Court noted that a State can change jury functions and even remove jury roles in some circumstances, and that a private party had no vested right to the usual division between judge and jury. Because Oklahoma’s Constitution left the negligence defense entirely to the jury and that constitution was in force when the death occurred, the Court affirmed the state court judgment for the woman.

Real world impact

The decision means that, at least under Oklahoma’s rule, juries rather than judges decide whether a victim’s own fault bars recovery. That outcome makes it harder for companies like railroads to win solely on a legal defense when juries might find differently. The ruling enforces the State’s choice about how civil cases are decided and leaves victims’ families able to rely on jury fact-finding to pursue claims.