Facts
- Dice, a railroad fireman, was seriously injured when the engine in which he was riding derailed.
- He sued the railroad in Ohio state court under the Federal Employers’ Liability Act (FELA), alleging the railroad’s negligence caused his injuries.
- The railroad denied negligence and asserted a written release purportedly settling all claims for $924.63.
- Dice admitted signing documents related to payments but claimed he did not agree to a full settlement.
- Dice alleged the release was procured by fraud because the railroad’s representative deliberately misrepresented it as only a receipt for back wages.
Issues
- In a FELA action brought in state court, is the validity of an employee’s release governed by federal law or state law?
- Under the governing law, is a FELA release void if induced by deliberate, material misrepresentations about the document’s contents?
- In a state-court FELA case providing for jury trial, may the judge decide the factual question of fraud in obtaining the release, or must the jury decide it?
Decision
- The Supreme Court reversed the Ohio Supreme Court and remanded.
- The validity of a FELA release is a federal question governed by federal law, not state law.
- A FELA release is void if the employee was induced to sign it by deliberately false and material statements by the carrier’s authorized representatives intended to deceive the employee about the release’s contents.
- It was error for the trial judge to remove from the jury the factual question whether the release was fraudulently obtained in a FELA case tried with a jury.
Legal Principles
- Federal law controls substantive questions that determine the enforceability of rights created by FELA, including defenses based on releases.
- State rules that would bind an employee to a release despite deliberate deception cannot restrict the enforcement of federal FELA rights.
- Where a FELA action is tried to a jury, factual disputes about fraud in the execution of a release must be submitted to the jury rather than resolved by the judge through post-verdict reweighing of evidence.
Conclusion
The Court held that federal law governs the validity of releases in FELA actions, that releases procured by deliberate material deception are void, and that in jury-tried FELA cases the jury must decide the factual question of fraudulent procurement.