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CSX Transportation, Inc. v. McBride

Supreme Court of the United States
131 S. Ct. 2630, 564 U.S. 685 (2011)
ELI5:

Rule of Law:

Under the Federal Employers' Liability Act (FELA), the standard for causation is met if the employer's negligence played any part, no matter how small, in bringing about the employee's injury; traditional common-law proximate cause standards do not apply.


Facts:

  • Robert McBride worked as a locomotive engineer for CSX Transportation, Inc.
  • On April 12, 2004, CSX assigned McBride to operate a train with an unusual engine configuration for a 'switching' run, which involves frequent starts and stops.
  • McBride protested to his superiors that the engine configuration was unsafe for switching because it required constant and difficult use of a hand-operated independent brake.
  • He was instructed to operate the train as configured, despite his safety concerns.
  • Approximately ten hours into the run, McBride injured his hand while using the hand-operated independent brake.
  • Despite two surgeries and extensive physical therapy, McBride never regained full use of his hand.

Procedural Posture:

  • Robert McBride sued CSX Transportation, Inc. in the U.S. District Court for the Southern District of Illinois under FELA.
  • At trial, CSX requested jury instructions on 'proximate cause,' which the trial court denied.
  • The court instead instructed the jury that CSX 'caused or contributed to' the injury if its negligence 'played a part — no matter how small — in bringing about the injury.'
  • The jury found for McBride but reduced his damages by one-third due to his own negligence.
  • CSX, as appellant, appealed to the U.S. Court of Appeals for the Seventh Circuit, arguing that the failure to instruct on proximate cause was error.
  • The Seventh Circuit affirmed the trial court's judgment, holding that the relaxed causation standard from Rogers v. Missouri Pacific R. Co. was correctly applied.
  • The U.S. Supreme Court granted certiorari to resolve the question of the proper causation standard in FELA cases.

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Issue:

Does the Federal Employers' Liability Act (FELA) require a jury instruction on traditional common-law proximate cause, as opposed to an instruction that liability exists if the railroad's negligence played any part, no matter how small, in causing the employee's injury?


Opinions:

Majority - Justice Ginsburg

No, FELA does not require a jury instruction on traditional common-law proximate cause. The statute's language, 'resulting in whole or in part,' and this Court's precedent in Rogers v. Missouri Pacific R. Co. establish a relaxed standard where the proper inquiry is simply whether the employer's negligence played any part, even the slightest, in producing the injury. The Rogers 'any part' test is a comprehensive statement of the FELA causation standard, intended by Congress to supplant the harsh and confusing common-law rules that made recovery difficult for injured workers. For over 50 years, federal courts have uniformly applied this standard, and considerations of stare decisis support its affirmation. While foreseeability of harm is an essential element of the underlying negligence claim, once negligence is proven, the railroad is liable for any injury its negligence played a part in causing, even if the specific manner or extent of the injury was not foreseeable.


Dissenting - Chief Justice Roberts

Yes, FELA should be interpreted to include the common-law requirement of proximate cause. By creating a federal tort action sounding in negligence, Congress is presumed to have adopted the background principles of common law, including proximate causation. The majority's 'any part' test is functionally equivalent to 'but for' causation, which provides no meaningful limit on liability. The statutory phrase 'in whole or in part' was intended to abrogate the common-law defense of contributory negligence, not to eliminate the fundamental requirement that a defendant's conduct be directly related to the injury. The Court's decision misreads Rogers, which addressed multiple causation in the context of comparative negligence, and abandons a centuries-old legal principle necessary to prevent liability for remote or fortuitous consequences.



Analysis:

This decision solidifies the long-standing, worker-friendly interpretation of causation under FELA, firmly rejecting attempts to import more restrictive common-law proximate cause standards into the statute. The Court's holding clarifies that the Rogers 'any part' test is the definitive standard for FELA causation, creating a clear split from other federal statutes like RICO or antitrust where traditional proximate cause is required. This ruling reinforces the remedial purpose of FELA and ensures a lower burden of proof on causation for injured railroad employees, thereby increasing the scope of potential liability for railroad employers. Future litigation will focus on the element of negligence itself, as the causal link is now governed by this less demanding standard.

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