Opinion · Supreme Court of the United States

Erie Railroad Company v. Winfield

244 U.S. 170

Type
Opinion
Court
Supreme Court of the United States
Jurisdiction
Federal
Date
1916-03-01
Topic
general

How later courts describe this case

  • finding 45 U.S.C. § 51 “is intended to operate uniformly in all states, as respects to interstate commerce, and in that field it is both paramount and exclusive”
  • employee riding a passenger train of employer to his job as a freight train flagman held outside the scope of employment
  • “In leaving the carrier’s yard at the close of his day’s work the deceased was but discharging a duty of his employment.”
  • employee injured while leaving rail yard after work

Citator

UpLaw has not yet analyzed Erie Railroad Company v. Winfield. The absence of a flag is not a finding that it is good law.

Cited by
282 opinions

Headnotes

  1. Labor & Employment Law — Federal Employers' Liability Act — Scope The duty of interstate railroad carriers to compensate employees for injury or death in interstate commerce is regulated uniformly and exclusively by the Federal Employers' Liability Act, which confines that duty to cases of causal negligence and excludes any obligation to compensate in the absence of negligence. 244 U.S. 170 (citing New York Central R.R. Co. v. Winfield, ante, 147)
  2. Labor & Employment Law — Preemption The Federal Employers' Liability Act is paramount and exclusive in the field of interstate commerce, operating uniformly in all States, and it is beyond the power of any State to interfere with its operation, either by putting carriers and their employees to an election between the federal act and a state statute or by imputing such an election to them through a statutory presumption. 244 U.S. 170
  3. Labor & Employment Law — Federal Employers' Liability Act — Course of Employment An employee whose day's work consists of switching freight cars in interstate and intrastate commerce is engaged in interstate commerce while leaving the carrier's yard at the close of his day's work, because that departure is a necessary incident of his employment and partakes of the character of his work as a whole. 244 U.S. 170 (citing North Carolina R.R. Co. v. Zachary, 232 U.S. 248, 260)
  4. Labor & Employment Law — Preemption A state statute providing compensation without regard to negligence cannot bind an interstate carrier by presuming the parties have agreed to be bound by it in the absence of a written declaration to the contrary, because the federal act has placed the entire subject beyond the reach of state laws. 244 U.S. 170