The Federal Employers’ Liability Act (FELA), 45 U. S. C. §51 et seq. renders railroads liable for employees’ injuries or deaths “resulting in whole or in part from [carrier] negligence.” This is basically in lieu of workers' compensation benefits for railroad employees covered by the FELA.
Robert McBride, a locomotive engineer, injured his hand while operating a manual brake. He brought suit against his employer, CSX.
The issue was what is the causation standard under the FELA. Must the railroad's negligence be the "proximate" cause of the injury (i.e., the harm was the probable consequence of the risk), or does some other standard apply?
The Court held that a much lower standard applies under FELA than under traditional negligence cases. Surveying years of precedent, the Court upheld the lower courts' jury instruction:
defendant railroad “caused or contributed to” a railroad worker’s injury “if [the railroad's] negligence played apart—no matter how small—in bringing about the injury.” That, indeed, is the test Congress prescribed for proximate causation in FELA cases.
Again, this decision is limited to injuries under the FELA. So, it is not applicable to most employers.
The case is CSX Transportation, Inc. v. McBride and the opinion is here.
