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

Summary

The court affirmed summary judgment for Union Pacific on the estate's Federal Employers' Liability Act wrongful-death claim arising from Phillip Morgan's suicide after alleged workplace harassment. It held that the claim was based on emotional injury caused by workplace stress and therefore was not compensable because Morgan neither suffered a physical impact nor faced an imminent risk of physical impact or harm at work. The court rejected arguments that the suicide itself constituted a qualifying physical injury, that FELA treated death differently from nonfatal emotional injury, or that Union Pacific's workplace "red zones" satisfied the governing zone-of-danger requirement.