Facts
- Robert McBride, a CSX Transportation locomotive engineer, operated braking controls while switching railroad cars.
- During switching work, McBride suffered a serious hand injury requiring multiple surgeries and resulting in long-term pain.
- McBride sued under the Federal Employers’ Liability Act (FELA), alleging CSX negligently required use of unsafe switching/braking equipment and failed to provide adequate training.
- At trial, the jury was instructed that CSX caused or contributed to the injury if its negligence played a part—no matter how small—in bringing about the injury.
- CSX requested a “proximate cause” instruction requiring a natural and probable sequence between negligence and injury; the district court refused, and the jury found for McBride, awarding damages.
Issues
- Whether FELA requires a common-law “proximate cause” instruction as an element of causation.
- Whether a jury instruction stating that railroad negligence is causal if it played any part, even the slightest, in producing the injury correctly states FELA causation.
Decision
- The Supreme Court affirmed the judgment for McBride in a 5–4 decision.
- The Court held that FELA does not require incorporation of traditional common-law proximate cause standards.
- The Court approved an instruction tracking FELA’s text as interpreted in Rogers v. Missouri Pacific R. Co.: negligence is causal if it played any part, even the slightest, in bringing about the injury.
- The Court noted that FELA remains a negligence statute, not strict liability; the plaintiff must still prove breach of duty and a causal contribution to the injury.
Legal Principles
- FELA imposes liability for injuries “resulting in whole or in part” from a railroad’s negligence, reflecting a relaxed causation standard compared to common-law tort actions.
- In a FELA case, the proper causation inquiry is whether the railroad’s negligence played any part, even the slightest, in producing the employee’s injury.
- A trial court does not err by refusing to instruct the jury on common-law proximate cause if the jury is properly instructed under the FELA/Rogers causation formulation.
- Concerns about limitless liability are addressed through ordinary negligence requirements (duty, breach, and causal contribution), rather than by importing common-law proximate cause terminology.
Conclusion
The Court held that FELA does not require a common-law proximate cause instruction and that juries may be instructed that a railroad caused or contributed to an employee’s injury if the railroad’s negligence played any part, even the slightest, in bringing about the injury.