Szabo v. Pennsylvania Railroad Co.
132 N.J.L. 331, 1945 N.J. LEXIS 157, 40 A.2d 562 (1945)
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Rule of Law:
When an employee becomes ill or injured during the course of employment and is rendered helpless to provide for their own care, the employer has a duty to provide such medical care and assistance as the emergency reasonably requires.
Facts:
- The plaintiff's husband was employed by the defendant-respondent as a laborer on a track maintenance crew.
- While working, the decedent was prostrated by the heat.
- As a result of the heat prostration, the decedent became powerless to help or care for himself.
- The defendant-respondent's foreman observed the decedent's condition and instructed him to cease working.
- The foreman directed two fellow employees to take the decedent to his home.
- The fellow employees had to physically support and assist the decedent into a vehicle.
- The decedent was taken home and left there alone without further care or attention.
- The decedent subsequently died.
Procedural Posture:
- The plaintiff-appellant (decedent's estate) sued the defendant-respondent (employer) in the Middlesex Common Pleas court, a trial court.
- The jury at the trial court returned a verdict in favor of the plaintiff-appellant.
- The defendant-respondent appealed the trial court's judgment to the Supreme Court (an intermediate appellate court).
- The Supreme Court reversed the judgment of the trial court.
- The plaintiff-appellant appealed the Supreme Court's reversal to this court (the Court of Errors and Appeals).
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Issue:
Does an employer have a duty to provide care and assistance to an employee who, while engaged in their work, becomes helpless and unable to provide for their own care?
Opinions:
Majority - Campbell, Chancellor
Yes. While generally there is no duty for an employer to provide medical care to an employee, an exception exists when an employee is rendered helpless by an on-the-job injury or illness. Based on principles of humanity and fair dealing, a legal duty arises for the master to provide such medical care or other assistance as the emergency may reasonably require to save the employee's life or prevent further harm. This duty is triggered when the emergency occurs in the presence of the employer or a supervising employee, and it lasts for the duration of the emergency. In this case, there was sufficient evidence for a jury to determine that the foreman knew or should have known of the decedent's helpless condition, creating an emergency that required more care than simply being sent home alone.
Analysis:
This decision establishes a significant common law exception to the traditional rule that employers owe no duty to provide medical aid to their employees. By grounding this duty in 'dictates of humanity' and implying it into every employment contract, the court expands employer liability for non-negligent injuries. The ruling holds that a supervisor's knowledge of an employee's helpless state is imputed to the employer, creating a duty to act reasonably in an emergency. This precedent influences workplace safety policies, requiring employers and their supervisors to respond appropriately when an employee becomes incapacitated on the job, regardless of the cause.
