## Facts

- Southern Pacific operated interstate passenger trains between San Francisco, California, and Ogden, Utah, using a dining car that routinely ran eastbound and then returned westbound.
- On August 5, 1900, an eastbound train’s delay prevented the dining car from reaching Ogden in time for its planned westbound run.
- The dining car was left on a siding at Promontory, Utah, to be picked up by the next westbound train.
- Johnson, a head brakeman on the westbound train, was directed to couple the locomotive to the dining car.
- The locomotive had a Janney automatic coupler; the dining car had a Miller hook; the devices were incompatible and would not couple automatically by impact.
- To connect them, Johnson went between the locomotive and dining car to make the coupling manually.
- During the coupling, Johnson’s hand was caught between the bumpers and crushed, resulting in amputation above the wrist.
- Johnson sued for personal injuries, alleging negligence and violation of the federal Safety Appliance Act based on the failure to provide properly equipped and compatible automatic couplers.

## Issues

1. Whether the Safety Appliance Act’s automatic-coupler requirement for “any car used in moving interstate traffic” applied to the locomotive involved in the coupling.
2. Whether a dining car regularly used in interstate service, but standing on a siding awaiting pickup for the next trip, was “used in moving interstate traffic” at the time of the accident.
3. Whether the Act required automatic couplers that would couple with each other by impact (compatibility), or merely required that each piece of equipment have some automatic coupler.
4. Whether, absent an applicable statutory violation, assumption of risk barred an employee’s recovery for injuries suffered while manually coupling equipment.

## Decision

- The federal trial court directed a verdict for Southern Pacific after Johnson presented his evidence.
- The Eighth Circuit affirmed the directed verdict for Southern Pacific.
- The court concluded the Safety Appliance Act did not provide a basis for liability on these facts under its reading of the statute.
- Because no actionable statutory violation was found, the common-law doctrine of assumption of risk remained a complete bar to Johnson’s claim.

## Legal Principles

- A directed verdict for the employer may be affirmed where, on the plaintiff’s evidence, no statutory duty is shown to apply and the employee’s injury falls within assumed risks of employment.
- Under the court’s narrow construction of the Safety Appliance Act, the automatic-coupler requirement was not treated as extending to the locomotive for purposes of this claim.
- Under the court’s approach, a car temporarily idle on a siding awaiting its next interstate assignment could be treated as not “used in moving interstate traffic” at the injury moment.
- Under the court’s approach, the presence of nonmatching couplers was not treated as a statutory noncompliance that displaced assumption of risk.

## Conclusion

The Eighth Circuit affirmed judgment for the railroad by construing the Safety Appliance Act narrowly and holding that, without a statutory violation applicable to the locomotive–dining car coupling and the dining car’s status at the time, Johnson’s injury was barred by assumption of risk.


Johnson v. S. Pac. Co., 117 F. 462 (8th Cir. 1902)