New York Central Railroad v. Mohney

Background

Mohney, an engineer employed by a railroad in Ohio, was riding on a company train when a following section ran past warning signals and crashed into his car, causing serious injury. He held an annual employee pass that on its face was valid only for travel between two Ohio points. He had planned to continue to Pittsburgh using a separate interstate ticket or a pass to be left for him at Youngstown, but he rode the shorter route to Cleveland and presented his intrastate pass. Mohney sued the railroad after a trial court found the pass’s release void under Ohio public policy and entered judgment for him.

Reasoning

The Supreme Court explained that the written pass was a contract limited to intrastate travel and that the passenger’s private intent to continue into another State did not change those written terms. The Court held the railroad could not rely on the pass’s broad release because the state law and the contract’s express terms controlled. The Court also found sufficient evidence that the accident resulted from willful or wanton negligence by the railroad’s crew, and said that such conduct cannot be excused by a release.

Real world impact

The decision means written intrastate passes govern when their terms are clear and that carriers remain liable for willful or wanton misconduct despite release language. Passengers and employees who rely on intrastate passes may still recover for egregious crew negligence. The ruling does not finally decide all interstate-pass questions involving employment-issued passes.

Dissents or concurrances

Two Justices agreed with the judgment but said Mohney was an interstate passenger and Ohio law did not apply; they still agreed that willful or wanton negligence cannot be covered by a release.