Norfolk Southern R. Co. v. Sorrell, 549 U.S. 158 (2007)
Primary Holding
The causation standard under the Federal Employers’ Liability Act (FELA) must be the same for both railroad negligence and employee contributory negligence, meaning that the same standard of causation applies to both parties in determining liability.
In the case of Norfolk Southern R. Co. v. Sorrell, a railroad worker named Timothy Sorrell was injured on the job and sued his employer, Norfolk Southern, claiming their negligence caused his injuries. The Supreme Court decided that the rules for proving negligence should be the same for both the railroad and the employee, meaning if either party is found to be at fault, the same standard applies. This ruling helps protect workers by ensuring that they can seek compensation fairly, without facing stricter rules just because they might have contributed to the accident themselves. This case is important for workers injured on the job, especially in the railroad industry, as it clarifies how negligence is assessed in these situations.
AI-generated plain-language summary to help you understand this case
In the case of Norfolk Southern R. Co. v. Sorrell, Timothy Sorrell, an employee of Norfolk Southern Railway Company, sustained neck and back injuries while operating a dump truck loaded with asphalt on November 1, 1999. The incident occurred while he was driving on a gravel road alongside the railroad tracks in Indiana. Sorrell's truck tipped over after veering off the road, leading to his injuries. The circumstances surrounding the accident were disputed; Sorrell claimed that another Norfolk employee, Keith Woodin, forced his truck off the road, while Woodin contended that Sorrell drove into a ditch. Sorrell filed a lawsuit against Norfolk Southern in Missouri state court on June 18, 2002, under the Federal Employers’ Liability Act (FELA), alleging that the company failed to provide a safe working environment and that its negligence caused his injuries. Norfolk Southern argued that Sorrell's own negligence contributed to the accident. The case involved a significant procedural issue regarding the jury instructions on causation standards for negligence. Missouri's jury instructions differentiated between the standards for railroad negligence and employee contributory negligence, which Norfolk Southern contended was improper under FELA's comparative fault system. The trial court denied Norfolk's objections to the jury instructions, and after the jury awarded Sorrell $1.5 million in damages, Norfolk moved for a new trial based on the same argument regarding the differing causation standards. The trial court denied this motion, and the Missouri Court of Appeals affirmed the decision, rejecting Norfolk's assertion that the causation standard should be uniform for both the railroad and the employee. This led Norfolk Southern to seek a writ of certiorari to the Supreme Court, which ultimately addressed the issue of causation standards under FELA.
Whether the causation standard under the Federal Employers’ Liability Act (FELA) should be the same for both railroad negligence and employee contributory negligence.
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- October 10, 2006
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Roberts
- Damages Awarded
- N/A
- Data Quality
- high
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