CSX Transportation, Inc. v. McBride

Supreme Court of the United States · 2011 · Torts

TortsFELAcausationproximate causeFELAcausationproximate causeRogers test

Facts

Robert McBride, a locomotive engineer for CSX, was assigned to operate a train with an unusual engine configuration that he protested was unsafe for switching because it required constant use of a hand-operated independent brake. About ten hours into the run, he injured his hand while using that brake and never regained full use despite surgeries and therapy. In his FELA action, McBride alleged CSX was negligent in requiring unsafe equipment for switching and in failing to train him to operate it. The district court 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, and refused CSX's requested proximate-cause instructions.

Issue

In a FELA case, must the jury be instructed using traditional common-law proximate cause terminology, or is it enough to instruct that the railroad caused the injury if its negligence played any part, even the slightest, in bringing about the employee's injury?

Rule

FELA does not incorporate common-law proximate cause standards developed in nonstatutory tort actions. The proper causation instruction tracks the statute: a railroad caused or contributed to the employee's injury if the railroad's negligence played any part, even the slightest, in bringing about the injury.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Evan Ortiz, a brakeman for Great Plains Freight Rail, was injured while lifting a misaligned coupler in Omaha, Nebraska. At trial under FELA, he presented evidence that the railroad negligently failed to maintain the coupler and that this negligence contributed to the strain in his shoulder.

Which jury instruction on causation is most appropriate?

Explanation. In a FELA case, the proper causation charge tracks the statute and Rogers: the railroad is liable if its negligence played any part, even the slightest, in bringing about the employee's injury. The majority held that traditional common-law proximate-cause formulations such as 'natural and probable,' 'direct,' or 'sole efficient producing cause' need not be given and may be refused. (Derived from CSX Transportation, Inc. v. McBride (2011).)