FEDERAL EMPLOYERS’ LIABILITY ACT

BNSF Railway Co. v. Tyrrell

Issues

Can a railroad corporation be sued under the Federal Employers’ Liability Act by an employee for compensation for injuries in a state that is neither the home state of the corporation nor where the injuries occurred?

Court below

Petitioner Kelli Tyrrell (“Tyrrell”) sued BNSF Railway Company (“BNSF”) in Montana state court, alleging violations of the Federal Employer’s Liability Act (“FELA”) for the injuries Brent Tyrrell sustained while working at BNSF. Robert Nelson also sued BNSF in Montana for FELA violations for the knee injuries he experienced while under BNSF’s employ. The Supreme Court consolidated Tyrrell’s and Nelson’s FELA claims. BNSF argues that Montana courts do not have personal jurisdiction over these claims because BNSF is not incorporated in Montana, Montana is not BNSF’s principal place of business, the petitioners are not Montana residents, and the claims did not arise in Montana. Tyrrell and Nelson counter that state courts have the authority to exercise personal jurisdiction over out-of-state corporations in federal claims, like FELA, when the state law permits such a claim. This case allows the Supreme Court to define the boundaries of state courts’ personal jurisdiction over out-of-state defendants in federal claims. 

Questions as Framed for the Court by the Parties

Whether, notwithstanding this Court’s decision in Daimler AG v. Bauman, 134 S. Ct. 746 (2014), a state court can exercise personal jurisdiction over a defendant railroad that is not at home in the state, in a case that does not arise in the state, on the ground that the plaintiff pleads a cause of action under the Federal Employers’ Liability Act and the railroad is not incorporated overseas. 

In May 2014, Kelli Tyrrell (“Tyrrell”), the special administrator for the estate of Brent Tyrrell (“Brent”), sued BNSF Railway Company alleging violations of the Federal Employer’s Liability Act (“FELA”) for injuries Brent experienced while working for BNSF that ultimately led to his death. See Tyrrell v. BNSF Ry.

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CSX Transportation v. McBride

Issues

Whether the Federal Employers’ Liability Act requires proof of proximate causation in order for a railroad employee to recover for a workplace injury, or whether the employee is only required to show that the employer played some role in causing the injury.

 

Respondent Robert McBride, a railroad engineer for Petitioner CSX Transportation Inc. (“CSX”), sued CSX under the Federal Employers’ Liability Act (“FELA”), claiming that CSX was responsible for a hand injury that McBride suffered while operating the brakes of a train. In its appeal of the jury’s verdict in favor of McBride, CSX alleges that proximate causation is required for recovery under FELA. McBride contends that proximate causation is not the proper standard of causation, based on recent rulings made by the U.S. Supreme Court and the U.S. Courts of Appeals. CSX also argues that public policy supports use of a proximate cause standard, while McBride argues that requiring proximate causation actually discourages employers from maintaining safe workplaces. The Supreme Court’s ruling will elucidate the proper standard of causation required under FELA.

Questions as Framed for the Court by the Parties

Whether the Federal Employers’ Liability Act, 45 U.S.C. §§ 51-60, requires proof of proximate causation.

Petitioner CSX Transportation, Inc. (“CSX”) is a railroad company. See McBride v. CSX Transportation, Inc., 598 F.3d 388, 389 (7th Cir.

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Additional Resources

Bloomberg, Greg Stohr: Railroad Worker Injury Clash Draws U.S. Supreme Court Review (Nov. 29, 2010)

The Daily Record, Kimberly Atkins: Justices Take CSX Case on Causation Standard (Nov. 29, 2010)

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Southwest Airlines Co. v. Saxon

Issues

Are airline cargo loaders and their supervisors, who load and unload goods from planes that cross international or interstate borders but do not physically transport such goods themselves, “transportation workers” who are exempt from arbitration under Section 1 of the Federal Arbitration Act?

This case asks the Supreme Court whether an airline ramp supervisor is exempt from arbitration under the Federal Arbitration Act. The Federal Arbitration Act codifies the federal policy for disputes to go through arbitration, exempting workers that engage in interstate commerce. Southwest Airlines argues that Saxon must resolve her dispute through arbitration because Saxon is not an exempt employee under the Act. Saxon argues that her work as a ramp supervisor includes loading and unloading cargo that travels interstate, so she is exempt from mandatory arbitration. The outcome of this case has implications for defining the limits of the Federal Arbitration Act and how courts define a worker operating in interstate commerce.

Questions as Framed for the Court by the Parties

Whether workers who load or unload goods from vehicles that travel in interstate commerce, but do not physically transport such goods themselves, are interstate “transportation workers” exempt from the Federal Arbitration Act.

Latrice Saxon is a Southwest Airlines (“Southwest”) ramp supervisor that manages the loading and unloading of passenger luggage. Saxon v. Sw. Airlines Co. at 494. As a ramp supervisor, Saxon trains, supervises, and occasionally assists ramp agents with loading and unloading cargo. Id.

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