## Facts

- Rigsby, a switchman for Texas & Pacific Railway, worked in the Marshall, Texas yard.
- The crew moved three “bad order” (defective) cars from a spur track onto a main line used daily by interstate freight and passenger trains.
- Rigsby rode atop a boxcar to set the handbrake and then began descending its ladder.
- A defective handhold (grab iron) associated with the ladder gave way, causing Rigsby to fall and suffer injuries.
- The boxcar had been out of service on the spur for days or weeks and was marked “bad order.”
- Rigsby sued under the Federal Safety Appliance Acts, which required rail cars to have secure ladders, running boards, and handholds/grab irons.
- The trial court directed a verdict for Rigsby on liability and sent only damages to the jury; the court of appeals affirmed.

## Issues

1. Whether a railroad employee injured by a defective safety appliance required by federal statute may recover damages even if he was not engaged in interstate commerce at the moment of injury and the car was being moved for repair as “bad order.”
2. Whether the Safety Appliance Acts impose civil liability without proof of carrier negligence and bar an assumption-of-risk defense based on the employee’s knowledge of the defect.
3. Whether the statutory provision suspending penalties while a defective car is hauled to repair relieves the carrier from civil liability for injuries occurring during that movement.

## Decision

- The Supreme Court affirmed the judgment for Rigsby.
- A violation of the Safety Appliance Acts is a wrongful act that supports an implied damages action by an injured member of the protected class.
- The Acts apply to cars on railroads that function as highways of interstate commerce, regardless of the particular car’s use at the moment or whether the employee’s task is intrastate.
- The carrier’s duty to maintain required appliances in secure condition is absolute; negligence is immaterial.
- Statutory limits on penalties for hauling a defective car to the nearest repair point do not eliminate civil liability for injuries caused during that movement.

## Legal Principles

- When a federal safety statute is enacted for the special benefit of a class, violation causing injury to a class member implies a right to recover damages from the violator (*ubi jus ibi remedium*).
- The Safety Appliance Acts impose an absolute and nondelegable duty on interstate carriers to equip and maintain required appliances in secure condition.
- Liability under the Acts does not depend on proof of negligence.
- Employee knowledge of the defect does not constitute assumption of risk where the statute removes that defense.
- A statutory suspension of penalties for moving defective equipment to repair does not bar remedial civil actions for resulting employee injuries.

## Conclusion

The Court held that an injured railroad employee may recover damages for injuries caused by defective, federally required safety appliances, even during repair-related movements and irrespective of negligence or the employee’s contemporaneous involvement in interstate transportation.


Texas & Pac. Ry. Co. v. Rigsby, 241 U.S. 33 (1916)