Dice v. Akron, Canton & Youngstown Railroad Co.
Facts
Petitioner, a railroad fireman, was seriously injured when the engine he was riding derailed. He sued respondent under FELA, and respondent defended on the ground that petitioner had signed a written release settling all claims for $924.63. Petitioner admitted signing several receipts connected to payments after his injury but claimed the supposed release was void because he signed it in reliance on respondent's deliberately false statement that the document was only a receipt for back wages. The jury found for petitioner and awarded $25,000, but the trial judge set aside the verdict after reappraising the evidence on fraud.
Issue
Whether the validity of a release asserted as a defense to a FELA claim is governed by federal or state law, and whether a state may have the judge rather than the jury decide factual issues concerning fraud in such a release when the case otherwise receives a jury trial.
Rule
Under FELA, the validity of a release is a federal question governed by uniform federal law, not state law. A release of rights under the Act is void when the employee is induced to sign it by deliberately false and material statements of the railroad's authorized representatives made to deceive the employee as to the contents of the release. Where there is conflicting evidence on fraud, the employee's right to jury trial on that issue is a substantial part of the FELA remedy and cannot be denied as a mere local rule of procedure.
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Which law should the court apply to determine whether the release bars Evan's FELA claim?