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Armstrong v. Kansas City Southern Railway Co.

Court of Appeals for the Fifth Circuit
752 F.2d 1110 (1985)
ELI5:

Rule of Law:

Under the Federal Employers' Liability Act (FELA), a railroad is liable for employee injuries if its negligence played even the slightest part in causing the injury, whereas state law indemnity claims typically require proof of proximate cause; therefore, a railroad may be found liable to an employee for an agent's actions yet be denied indemnity from that agent if the agent's negligence was not the proximate cause of the accident.


Facts:

  • Armstrong, a brakeman for the Louisiana & Arkansas Railway Co. (L & A), was working on a freight run from New Orleans to Alexandria, Louisiana.
  • In the early morning hours, L & A ordered Armstrong to disembark the train to move cars on a side track.
  • L & A followed its custom of summoning a taxicab from Miller Cab Company (Miller) to transport Armstrong and a coworker to the yard office.
  • The Miller cab driver stopped the vehicle in the eastbound lane of the road, approximately five feet from the railroad track, rather than pulling into a nearby parking lot or onto the shoulder.
  • Despite the darkness and an elevated railroad crossing that potentially obscured vision, the cab driver did not activate emergency flashing lights.
  • Armstrong entered the cab, and before he could close the door or fasten his seatbelt, another motorist struck the rear of the cab.
  • Armstrong suffered neck injuries as a result of the collision.

Procedural Posture:

  • Armstrong filed a civil suit against Kansas City Southern Railway Company (KCS) and L & A in the United States District Court seeking damages under FELA.
  • KCS and L & A filed a third-party complaint against Miller Cab Company and its insurer seeking indemnity.
  • The District Court held a jury trial for the FELA claim and a simultaneous bench trial for the indemnity claim.
  • The jury returned a verdict in favor of Armstrong and against the railroads on the FELA claim.
  • The District Court dismissed the railroads' third-party indemnity claim against Miller.
  • The railroads filed motions for judgment notwithstanding the verdict (JNOV) or a new trial.
  • The District Court denied the post-trial motions and granted a motion to delete KCS from the judgment.
  • L & A appealed the judgment to the United States Court of Appeals for the Fifth Circuit.

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Issue:

Does a jury finding of negligence against a railroad's agent under the relaxed causation standard of the Federal Employers' Liability Act mandate a finding of proximate cause necessary to award the railroad indemnity under state law?


Opinions:

Majority - Circuit Judge Robert Madden Hill

No, a finding of liability under FELA does not automatically entitle the railroad to indemnity under state law because the two actions are governed by distinct causation standards. The Court affirmed the district court's judgment, explaining that FELA liability attaches if employer negligence plays 'any part, even the slightest' in producing the injury. This is a significantly lower burden than the common-law 'proximate cause' standard required for the state law indemnity claim. Consequently, the jury could validly find the railroad liable under FELA based on the cab driver's slight negligence (stopping on the road), while the district judge could simultaneously finding that, under Louisiana law, the cab driver's actions were not the proximate cause of the accident (assigning sole fault to the rear-ending motorist). The appellate court defers to the trial court's factual findings unless clearly erroneous, and the record supported the judge's conclusion that the oncoming motorist should have seen the stopped vehicle.



Analysis:

This case illustrates the perilous legal position of railroads under FELA. Because FELA was designed to protect workers, it removed many common-law defenses and lowered the causation bar to a 'featherweight' standard. However, when a railroad attempts to shift the cost of that liability to a third party (like the cab company here), they step back into the realm of state common law, which uses the stricter 'proximate cause' standard. This creates a 'gap' where a railroad can be liable for an accident that it cannot legally blame on the third party who actually performed the negligent act. The decision reinforces that federal statutory liability and state common law indemnity are separate legal inquiries that can yield factually divergent results regarding the same accident.

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