CSX TRANSPORTATION v. MCBRIDE

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Case Basics
Docket No. 
10-235
Petitioner 
CSX Transportation, Inc.
Respondent 
Robert McBride
Decided By 
Advocates
(for the petitioner)
(for the respondent)
Term:
Facts of the Case 

Locomotive engineer Robert McBride filed suit after contending that he injured his hand while adding and removing railroad cars for his employer, CSX Transportation, Inc. Under the Federal Employers' Liability Act, a rail carrier is liable for worker injuries that result from negligence by the carrier. A trial judge instructed the jury that CSX caused or contributed to McBride's injury if its negligence "played a part, no matter how small, in bringing about the injury." The jury found for McBride and awarded him $184,250.

CSX argued that McBride should have been required to prove that the company's alleged negligence was a cause of the injury. But the U.S. Court of Appeals for the Seventh Circuit disagreed, affirming the verdict.

Question 

Does the Federal Employers' Liability Act require proof of proximate causation?

Conclusion 
Decision: 5 votes for McBride, 4 vote(s) against
Legal provision: Federal Employers' Liability Act

No. The Supreme Court affirmed the lower court order in an opinion by Justice Ruth Bader Ginsburg. "The charge proper in FELA cases, we hold, simply tracks the language Congress employed, informing juries that a defendant railroad caused or contributed to a plaintiff employee's injury if the railroad's negligence played any part in bringing about the injury," Ginsburg wrote for the majority. Meanwhile, Chief Justice John Roberts dissented, joined by Justices Antonin Scalia, Anthony Kennedy and Samuel Alito. "The Court is wrong to dispense with that familiar element of an action seeking recovery for negligence, an element 'generally thought to be a necessary limitation on liability,'" Roberts wrote.

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CSX TRANSPORTATION v. MCBRIDE. The Oyez Project at IIT Chicago-Kent College of Law. 20 October 2014. <http://www.oyez.org/cases/2010-2019/2010/2010_10_235>.
CSX TRANSPORTATION v. MCBRIDE, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/2010-2019/2010/2010_10_235 (last visited October 20, 2014).
"CSX TRANSPORTATION v. MCBRIDE," The Oyez Project at IIT Chicago-Kent College of Law, accessed October 20, 2014, http://www.oyez.org/cases/2010-2019/2010/2010_10_235.