Opinion · Supreme Court of the United States

Coray v. Southern Pacific Co.

Coray v. S. Pac. Co., 335 U.S. 520 (1949)

Type
Opinion
Court
Supreme Court of the United States
Jurisdiction
Federal
Date
1949-01-03
Topic
general

How later courts describe this case

  • stating that FELA's "in whole or in part" language is "simple and direct"
  • rejecting use of common-law “dialectical subtleties” concerning the term “proximate cause,” and ap­ proving use of “simple and direct” statutory language
  • rejecting use of common-law “dialectical subtleties” concerning the term “proximate cause,” and approving use of “simple and direct” statutory language
  • “ [Petitioner was entitled to recover if this defective equipment was the sole or a contributory proximate cause of the decedent employee’s death”
  • FSAA must be interpreted “to protect all who need protection from dangerous results due to maintenance or operation of congressionally prohibited defective appliances”
  • if breach of Safety Appliance Act "contributes in part to an employee's death, the railroad must pay damages”
  • "Congress has thus for its own reasons imposed extraordinary safety obligations upon railroads and has commanded that if a breach of these obligations contributes in part to an employee's death, the railroad must pay damages."

Citator

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Cited by
151 opinions

Headnotes

  1. General — Federal Employers' Liability — Safety Appliance Act — Scope of Protection The Federal Safety Appliance Act's prohibition on operating trains with defective brakes is not limited to protecting employees from moving trains; an abrupt or unexpected stop caused by defective brakes may be equally dangerous, and the Act protects all persons who need protection from dangerous results flowing from the maintenance or operation of congressionally prohibited defective appliances, regardless of the employee's position or the work he was doing when injured. 335 U.S. at 522-523 (citing Fairport, P. & E.R. Co. v. Meredith, 292 U.S. 589, 597; Brady v. Terminal R. Assn., 303 U.S. 10, 16; Louisville & N.R. Co. v. Layton, 243 U.S. 617, 621)
  2. General — Federal Employers' Liability — Causation — Defective Appliances Where undisputed evidence establishes that a train stopped suddenly because of defective air-brake appliances maintained in violation of the Safety Appliance Act, the injured employee (or his administrator) is entitled to recover if the defective equipment was the sole or a contributory proximate cause of the employee's death. 335 U.S. at 523 (citing Davis v. Wolfe, 263 U.S. 239, 243; Spokane & I.E.R. Co. v. Campbell, 241 U.S. 497, 509-510)
  3. General — Federal Employers' Liability — Causation — "Resulting in Whole or in Part" Under 45 U.S.C. § 51, a railroad is liable for an employee's death resulting in whole or in part from defective appliances, and the statutory language is to be applied simply and directly without importation of dialectical distinctions between "proximate cause" in the legal sense and "cause" in the philosophic sense; where a Safety Appliance Act violation contributed to the employee's death, the employee is not to be held contributorily negligent under 45 U.S.C. § 53. 335 U.S. at 523-524
  4. General — Federal Employers' Liability — Sufficiency of Evidence — Directed Verdict Where a defective brake appliance caused a train to stop suddenly and unexpectedly, and a following motor-driven track car operated by an employee looking in another direction crashed into the train, the circumstances are inseparably related in time and space, and a jury could find that the employee's death resulted from any or all of those circumstances; it is therefore error to direct a verdict for the railroad. 335 U.S. at 524