Minneapolis & St. Louis Railroad Co. v. Bombolis

Supreme Court of the United States · 1916 · Federal Courts

Federal CourtsSeventh AmendmentState courtsFederal Employers' Liability ActSeventh Amendmentcivil jurystate courtsfederal rights

Facts

The suit was brought in a Minnesota state court under the Employers' Liability Act of 1908, as amended in 1910, to recover for the death of Nanos, allegedly caused by the railroad's negligence while he was employed in interstate commerce. Minnesota law provided that in civil cases, after twelve hours of deliberation without unanimity, five-sixths of the jury could return a verdict with the same legal effect as a unanimous common-law verdict. At trial, the court instructed the jury about that rule, and the railroad objected that because the claim arose under federal law, the Seventh Amendment required a common-law jury verdict. The objection was overruled, and the plaintiff prevailed.

Issue

Does the Seventh Amendment apply to a state legislature's authorization of less-than-unanimous civil jury verdicts and to a state court's use of that procedure when the state court is enforcing a federal cause of action under the Employers' Liability Act?

Rule

The Seventh Amendment requires a civil jury according to the course of the common law only in proceedings in courts of the United States. The first ten Amendments, including the Seventh, are limitations on federal action, not state action, and the Amendment does not regulate jury trials or verdict standards in state courts merely because the right enforced is created by federal law.

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In Cleveland, Ohio, Tessa Moran sued Lakefront Freight Lines in an Ohio state court under a federal workplace-injury statute. Ohio law permits a civil verdict by 10 of 12 jurors after extended deliberations, and the jury returned a 10-2 verdict for Tessa.

Lakefront argues the verdict is unconstitutional because the claim arises under federal law, so the Seventh Amendment required a unanimous common-law jury. How should the court rule?

Explanation. The controlling rule is that the Seventh Amendment applies only to proceedings in courts of the United States and limits only federal action. A state court enforcing a federally created right does not thereby become subject to the Seventh Amendment's common-law jury requirements. Thus a nonunanimous civil verdict allowed by state law is not unconstitutional solely because the claim arises under federal law. (Derived from Minneapolis & St. Louis Railroad Co. v. Bombolis (1916).)