## 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

1. Whether FELA requires a common-law “proximate cause” instruction as an element of causation.
2. 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.


CSX Transp., Inc. v. McBride, 564 U.S. 685 (2011)