Reed v. Director General of Railroads

Background

A widow sued a railroad after her husband, a crew member working in interstate commerce, was killed when a caboose was derailed in the railroad yard. The husband had been riding the front of the caboose to warn the engineer about a derailing device; the device was set and the caboose was derailed, crushing him between cars. The widow sued under the Federal Employers’ Liability Act seeking damages for his death.

Reasoning

The state supreme court held the husband had "assumed the risk" of the accident and ruled for the railroad. The United States Supreme Court disagreed. It explained that under the federal law the old common‑law defense that sometimes let employers avoid liability does not apply when a co‑worker’s negligence that the injured person could not have foreseen is the sole, direct and immediate cause of the injury. Because the death here resulted from such co‑worker negligence, the Court said the assumption‑of‑risk defense could not defeat the widow’s claim.

Real world impact

The decision lets the widow’s federal claim go forward and limits employers’ ability to use assumption‑of‑risk to block recovery in similar railroad workplace deaths. The case was reversed and sent back to the lower court for further proceedings consistent with this ruling, so the final outcome on damages was not decided here.