Estate of Phillip Raymond Morgan, by Administrator, Personal Representative, Kera Morgan v. Union Pacific Railroad…

Summary

The court affirmed summary judgment for Union Pacific, holding that the estate’s Federal Employers’ Liability Act claim arising from Phillip Morgan’s suicide was barred because his workplace injuries were emotional injuries not connected to a physical impact, physical harm, or imminent threat of such harm. The court applied the zone-of-danger limitation to claims for emotional injury and concluded that workplace harassment, stress, and a company-defined “red zone” did not place Morgan within that zone. The opinion did not treat the suicide’s physical consequences as a separate compensable injury under the Act.