Mondou v. New York, New Haven & Hartford Railroad Co.

Supreme Court of the United States · 1912 · Federal Courts

Federal CourtsCommerce ClausePreemptionState court enforcement of federal rightsFederal Employers' Liability Actinterstate commerceCommerce Clausenecessary and proper

Facts

Congress enacted a federal statute governing the liability of interstate railroad carriers for injuries to employees engaged in interstate commerce. The act displaced common-law rules by abolishing the fellow-servant defense, limiting contributory negligence and assumption of risk, allowing recovery for death, and invalidating contracts designed to exempt carriers from statutory liability. The cases before the Court involved attacks on Congress's power to enact those rules, the effect of the act on overlapping state law, and whether state courts with otherwise adequate jurisdiction had to hear such claims. In the Connecticut case, the state court declined jurisdiction on the view that the federal act either confined enforcement to federal courts or could be refused because it conflicted with state policy and would cause inconvenience.

Issue

May Congress, under its power over interstate commerce, regulate the liability of railroad carriers to employees engaged in that commerce through the rules contained in the act? If so, do those federal rules supersede state law covering the same subject, and must state courts of otherwise adequate jurisdiction enforce the federal rights as a matter of right?

Rule

Congress's commerce power extends to railroad carriers, their employees, and the conditions of employment affecting interstate transportation, so long as the regulation bears a real or substantial relation to interstate commerce. When Congress validly exercises that power, the federal statute is supreme and supersedes state law in the same field. State courts whose ordinary jurisdiction is adequate and whose regular procedures can adjudicate the claim must entertain federal causes of action arising under such a statute; they may not refuse because the federal policy differs from state policy or because applying federal law would be inconvenient.

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

Lakeshore Central Rail, a fictional railroad based in Cleveland, runs freight between Ohio and Pennsylvania. While coupling cars for a train bound to Erie, conductors employed on that interstate route challenge a federal statute requiring rail carriers engaged in interstate service to provide a damages remedy for injuries caused by unsafe staffing practices, arguing Congress cannot regulate the employer-employee relationship at all.

Which is the strongest response?

Explanation. The majority held that interstate transportation is commerce and that railroads, their employees, and the conditions under which they perform interstate transportation are instruments and agents of that commerce. Congress therefore may regulate carrier-employee relations when both are engaged in interstate commerce, provided the regulation bears a real or substantial relation to that commerce. (Derived from Mondou v. New York, New Haven & Hartford Railroad Co. (1912).)