Facts
- Timothy Sorrell worked for Norfolk Southern Railway as a trackman performing track maintenance duties.
- While driving a company dump truck during work on November 1, 1999, Sorrell swerved to avoid another company vehicle, crashed, and suffered serious injuries.
- Sorrell sued Norfolk Southern in Missouri state court under the Federal Employers’ Liability Act (FELA), alleging the railroad’s negligence caused his injuries.
- The trial court instructed the jury that railroad negligence caused injury if it “contributed in whole or in part” to the injury, but that employee contributory negligence reduced damages only if the employee’s negligence “directly contributed to cause” the injury.
- Norfolk Southern objected that the contributory-negligence instruction imposed a more demanding causation standard on the railroad than on the employee.
- The objection was overruled; the jury awarded Sorrell $1.5 million, and Missouri appellate courts affirmed.
Issues
- Whether FELA permits different causation standards for railroad negligence under 45 U.S.C. § 51 and employee contributory negligence under 45 U.S.C. § 53.
- Whether a state court may use jury instructions that apply a more demanding causation test to the employee’s contributory negligence than to the railroad’s negligence in a FELA case.
- Whether the Supreme Court should decide the substantive content of FELA causation (e.g., proximate cause versus a more relaxed standard) in resolving the symmetry question.
Decision
- The Supreme Court unanimously vacated the judgment and remanded.
- The Court held that the same causation standard applies to railroad negligence under FELA § 51 and to employee contributory negligence under FELA § 53.
- The Court ruled that Missouri’s use of different instruction language for the two causation inquiries was inconsistent with FELA’s federal standard.
- The Court declined to decide what the substantive causation standard under FELA is, limiting its holding to the requirement of symmetry.
Legal Principles
- In FELA actions, causation for the railroad’s negligence and causation for the employee’s contributory negligence must be measured by the same legal standard.
- Because FELA is federal law, state courts adjudicating FELA claims may not alter the federal causation framework by imposing asymmetric causation burdens through jury instructions.
- Absent express statutory departure, FELA incorporates common-law negligence principles, including the common-law approach that used the same causation standard for defendant negligence and plaintiff contributory negligence.
- The decision does not resolve whether FELA requires traditional proximate cause or a less demanding causal connection; it requires only that whatever standard applies, it applies equally to both sides’ negligence.
Conclusion
The Court held that FELA requires a uniform causation standard for both railroad negligence and employee contributory negligence, making it error to instruct juries with a stricter causation test for the employee than for the railroad, and it remanded without defining the precise substantive causation standard under FELA.