Ives v. South Buffalo Railway Co.

New York Court of Appeals · Torts

TortsWorkers' compensationDue processPolice powerEmployer liabilitydue processpolice powerworkers' compensation

Facts

In 1910 the legislature enacted article 14-a of the Labor Law, modeled on the English Workmen's Compensation Act, after recommendations from the Wainwright Commission. The statute applied to specified dangerous industries and made an employer liable for employee injuries arising out of and in the course of employment from necessary or inherent risks, even if the employer was not at fault and even if the employee was at fault, unless the employee's conduct amounted to serious and willful misconduct. The defendant was a railroad corporation, but the statute applied generally to employers in enumerated occupations regardless of whether they were corporations, firms, or individuals. The dispute required the court to decide whether this new liability scheme was constitutional.

Issue

May the legislature, consistently with the Federal and New York due process guarantees and under the police power, require employers in specified hazardous industries to compensate employees for accidental injuries caused by inherent risks of the work even when the employer has committed no fault? More broadly, can the state impose this form of liability merely because the employment is dangerous?

Rule

Due process forbids the legislature from taking one person's property and giving it to another by imposing liability on a person who has violated no law and committed no fault, unless the enactment is otherwise justified within constitutional limits. Police power legislation is valid only if its operation tends in some degree to prevent an offense or evil or to preserve public health, morals, safety, or welfare, and if the means are reasonably necessary to that end and not unduly oppressive. While the legislature may alter remedies and may regulate or abolish common-law doctrines such as the fellow-servant rule and contributory negligence, it cannot make a faultless employer liable for accidental injuries solely because the employment is inherently dangerous.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

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

Colorado enacts a statute covering mining, steel fabrication, and bridge demolition. It requires every employer in those listed trades to pay an injured employee fixed compensation for any accidental injury arising from a necessary or inherent risk of the work, even if the employer used every available safety device and committed no negligence; the employer avoids liability only if the employee engaged in serious and willful misconduct. Nora Kim is injured when a properly maintained steel cable snaps during routine demolition work in Denver.

If Nora sues under the statute, what is the strongest constitutional objection under the majority's reasoning?

Explanation. The majority held unconstitutional the core feature of a law that makes an employer liable for accidental workplace injuries arising from inherent risks even when the employer has violated no duty and committed no fault. In the majority's view, that is taking A's property and giving it to B without due process. The court expressly distinguished this from mere procedural change or abolition of defenses. (Derived from Ives v. South Buffalo Railway Co. (n.d.).)