## Facts

- Jacob White was employed by a railroad and was accidentally killed in the course of his employment while guarding tools and materials intended for construction of a new station and tracks.
- White’s widow sought benefits under New York’s Workmen’s Compensation Law, which imposed no-fault, scheduled compensation and made the statutory remedy exclusive for covered employments.
- An administrative award of compensation was entered and affirmed by New York courts, including the state’s highest court.
- The railroad sought Supreme Court review, contending the statute was unconstitutional under the Fourteenth Amendment and arguing federal law (FELA) governed because the work related to future interstate commerce.

## Issues

1. Whether the employee’s work had a sufficiently direct relation to interstate transportation to bring the claim under the Federal Employers’ Liability Act rather than state compensation law.
2. Whether a state may impose no-fault, compulsory, exclusive workers’ compensation liability on employers and replace common-law negligence actions and defenses without violating due process.
3. Whether limiting covered employments and excluding classes such as farm laborers and domestic servants denies equal protection.

## Decision

- The Court held FELA did not apply because guarding tools and materials for construction of future facilities to be used in interstate commerce lacked a direct relation to interstate transportation.
- The Court upheld the New York Workmen’s Compensation Law against due process challenges by both employer and employee/dependents, rejecting claims of unconstitutional deprivation of property.
- The Court upheld the statute’s classifications, including the exclusion of farm laborers and domestic servants, as not an arbitrary denial of equal protection.
- The Court affirmed the judgment sustaining the compensation award.

## Legal Principles

- A state may replace fault-based workplace injury litigation with an exclusive, no-fault compensation system that provides scheduled benefits, without violating substantive due process, when the substitute remedy is reasonably just.
- Employers have no vested constitutional right to retain common-law defenses (including contributory negligence, assumption of risk, and the fellow-servant rule) against workplace injury claims.
- Employees and dependents have no vested constitutional right to pursue potentially larger common-law tort damages when the state provides a fair substitute remedy through compensation.
- Equal protection permits legislative line-drawing in coverage for compensation schemes; excluding certain worker categories is valid if not arbitrary and supported by a rational basis.
- FELA applies only when the employee’s work bears a direct relation to interstate transportation; work tied only to future interstate use is insufficient.

## Conclusion

The Court sustained New York’s compulsory, exclusive workers’ compensation system as a permissible legislative adjustment of employer and employee rights that provided a reasonable substitute for common-law remedies, and it rejected equal protection and FELA-based objections to applying the statute to the fatal workplace accident.


New York Cent. R.R. Co. v. White, 243 U.S. 188 (1917)