Anderson v. Carnegie Steel Co.
99 A. 215, 255 Pa. 33, 1916 Pa. LEXIS 522 (1916)
Sections
Rule of Law:
A state legislature may constitutionally abolish common law defenses and establish a workers' compensation scheme that replaces civil lawsuits with statutory benefits, provided the system is elective and allows parties to opt out.
Facts:
- William Anderson was employed by the Carnegie Steel Company.
- On January 12, 1916, Anderson was working in the course of his employment for the company.
- While performing his job duties on that date, Anderson sustained personal injuries.
Procedural Posture:
- Anderson filed a civil action against Carnegie Steel Company in the lower court to recover damages for his injuries.
- Carnegie Steel filed an affidavit of defense asserting that the Workmen's Compensation Act was the exclusive remedy.
- The trial court ruled in favor of Carnegie Steel, entering judgment for the defendant based on the Act.
- Anderson appealed the judgment to the Supreme Court of Pennsylvania.
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Issue:
Is the Workmen's Compensation Act of 1915 constitutional, specifically regarding whether abolishing common law defenses and substituting a statutory compensation schedule for a jury trial violates the Due Process Clause or the right to a trial by jury?
Opinions:
Majority - Chief Justice Brown
Yes, the Workmen's Compensation Act is constitutional because individuals possess no vested property right in common law rules, and the Act's waiver of jury trials is valid as it relies on the voluntary consent of the parties. The Court reasoned that while property rights acquired under the common law are protected, the law itself is subject to legislative change. The legislature has the power to abolish defenses such as the fellow servant rule and assumption of risk. Regarding the right to a jury trial and limits on recovery, the Court emphasized that the Act is not mandatory but elective. The statute creates a conclusive presumption that parties accept the compensation scheme unless they provide written notice to the contrary. Since the parties did not opt out, they voluntarily waived their right to a jury trial and agreed to the liability limits. Therefore, there is no violation of the state or federal constitution.
Analysis:
This case is a foundational decision regarding the constitutionality of Workers' Compensation schemes in the United States. By validating the 'elective' nature of the Act, the court navigated around strict constitutional protections for jury trials and prohibitions on limiting damages. The decision affirms the legislature's broad police power to modify common law tort principles to address modern industrial relations. It established that 'due process' does not freeze the common law in time, allowing states to replace negligence-based litigation with administrative compensation systems, provided there is a mechanism for voluntary participation—even if that participation is presumed by silence.
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