Supreme Court of the United States
Norfolk Southern Railway Co. v. Sorrell
January 10, 2007549 U.S. 158
Summary
The Court held that the Federal Employers' Liability Act requires the same causation standard for railroad negligence and employee contributory negligence. It vacated the Missouri Court of Appeals' judgment because Missouri applied different standards, leaving that court to determine whether the instructional error required a new trial. The Court expressly declined to decide the substantive content of the common causation standard. Justice Souter, joined by Justices Scalia and Alito, concurred, arguing that Rogers addressed multiple causes rather than relaxing the traditional requirement of proximate causation. Justice Ginsburg concurred in the judgment without joining the Court's opinion, emphasizing that existing precedent established a relaxed FELA causation standard and suggesting that the instructional error was almost certainly harmless.
Holding
- Whether railroad negligence and employee contributory negligence may be evaluated under different causation standards in a FELA action.. The same causation standard applies to railroad negligence under Section 1 and employee contributory negligence under Section 3 of FELA.
Docket 05-746
Cited authorities
- 45 U.S.C. §§ 51-60
- 35 Stat. 65
- 45 U.S.C. §§ 51-60
- 45 U.S.C. § 51
- 45 U.S.C. § 53
- 45 U.S.C. § 51
- 45 U.S.C. § 53
- 54 Vand. L. Rev. 941
Cited by
- Sean Van Buren v. Kansas City Southern Railway Company
- Donald J. Butynski, Plaintiff, Appellant v. Springfield Terminal Railway Company, Defendant, Appellee
- Milan v. New Jersey Transit Rail Operations, Inc.
- Tozzi v. Port Authority Trans Hudson Corp.
- Bias v. Foster
- Faford v. Grand Trunk Western Railroad Company
- Pfaffle v. Bnsf Railway Company
- Hodgson, Micheal v. Wisconsin Central, Ltd.