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WORKERS COMPENSATION

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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