## Facts

- Brown, a railroad employee, brought a negligence action against Western Railway of Alabama under the Federal Employers’ Liability Act (FELA) in Georgia state court.
- He alleged that, while performing his duties in the railroad yard, he stepped on a large clinker lying alongside the track and was injured.
- The complaint alleged the clinker or similar debris was negligently left where employees were required to work and that the railroad knew or should have known it created a dangerous condition.
- The railroad filed a general demurrer contending the complaint did not state a legal cause of action.
- Georgia courts construed the pleading “most strongly against the pleader,” inferred Brown could have seen and avoided the clinker, and treated the complaint as failing to allege actionable railroad negligence.

## Issues

1. Whether a state court may, using a local rule construing pleadings against the pleader, dismiss with prejudice a FELA complaint that—fairly construed—alleges employer negligence and causation.
2. Whether the state court’s dismissal on general demurrer improperly deprived the plaintiff of the federal right to have FELA negligence and causation issues decided by a jury.

## Decision

- The Supreme Court reversed the Georgia Court of Appeals and remanded.
- The Court held it was not bound by the state court’s construction of the complaint when determining whether a federal right granted by Congress had been denied.
- Construing the allegations as a whole, the Court concluded the complaint stated a cause of action under FELA and should not have been dismissed on general demurrer.
- A dissent would have deferred to the state courts’ application of their own pleading rules and rejected Supreme Court reexamination of the complaint’s sufficiency.

## Legal Principles

- Federal rights created by FELA, including the right to jury determination of fact issues such as negligence and causation, may not be defeated or burdened by state procedural or pleading doctrines.
- When a state court’s pleading construction threatens to deny a federal statutory right, the Supreme Court may independently construe the complaint to determine whether the federal right has been impaired.
- In FELA cases, allegations that the railroad negligently permitted a dangerous condition in the work area and that the condition caused injury are generally sufficient to require jury resolution rather than dismissal based on inferences against the plaintiff.

## Conclusion

The Court held that Georgia’s rule construing pleadings against the pleader could not be used to terminate a FELA action where the complaint, fairly read, alleged railroad negligence and injury causation; dismissing the case on general demurrer improperly withheld the federally protected jury determination of disputed fact questions.


Brown v. W. Ry. of Ala., 338 U.S. 294 (1949)