## Facts

- Gerald L. Morgan, a brakeman and conductor for Monessen Southwestern Railway Company, suffered a permanent back injury while working.
- Morgan returned to work in a less physically demanding job with fewer opportunities for additional compensation.
- Morgan sued Monessen in Pennsylvania state court under the Federal Employers’ Liability Act (FELA), alleging employer negligence and impaired future earning capacity.
- At trial, Morgan sought damages for loss of future earnings.
- The trial judge refused to instruct the jury to reduce any future earnings award to present value, stating there need not be such a reduction and effectively using a “total offset” approach.
- After the jury returned a verdict for Morgan, the court added prejudgment interest as “damages for delay” under Pennsylvania Rule of Civil Procedure 238 (10% per year for a defined pre-verdict period).
- Pennsylvania appellate courts affirmed, treating the discounting question as governed by federal law but upholding the instruction, and treating Rule 238 as procedural and not inconsistent with FELA.

## Issues

1. Whether a state court may award prejudgment interest (or “damages for delay”) under a state rule in a FELA action, or whether federal law exclusively controls the availability of such damages.
2. Whether, in a FELA case, a trial court may refuse to instruct the jury to discount future lost earnings to present value and instead apply a “total offset” method.

## Decision

- The Supreme Court reversed and remanded.
- The Court held that the measure of damages in FELA actions, including whether prejudgment interest is available, is a question of substantive federal law.
- The Court held that prejudgment interest is not authorized in FELA actions and state rules cannot add it to a FELA recovery.
- The Court held that FELA requires future economic losses to be reduced to present value and that the trial court erred by telling the jury no reduction was required.

## Legal Principles

- In FELA actions, the measure of damages is substantive federal law that state courts must apply.
- Absent congressional authorization, prejudgment interest is not recoverable in FELA personal injury actions, and a state “delay damages” rule cannot be used to increase a FELA award.
- Awards for future loss of earnings in FELA cases must be discounted to present value, and juries must be instructed to perform (or be guided in) that reduction; an instruction eliminating the present-value reduction is improper.

## Conclusion

The Court required uniform federal rules for FELA damages: state courts may not add prejudgment interest through state delay-damages provisions, and future earnings awards must be reduced to present value through proper jury instructions.


Monessen Southwestern Ry. Co. v. Morgan, 486 U.S. 330 (1988)