395 U.S. 164 (1969), 791, Crane v. Cedar Rapids & Iowa City Railway Co.
| Docket Nº: | No. 791 |
| Citation: | 395 U.S. 164, 89 S.Ct. 1706, 23 L.Ed.2d 176 |
| Party Name: | Crane v. Cedar Rapids & Iowa City Railway Co. |
| Case Date: | May 26, 1969 |
| Court: | United States Supreme Court |
Page 164
Argued April 24, 1969
CERTIORARI TO THE SUPREME COURT OF IOWA
Syllabus
The Federal Safety Appliance Act of 1833 requires interstate railroads to equip freight cars "with couplers coupling automatically by impact," but does not create a federal cause of action for employees or nonemployees seeking damages for injuries resulting from a railroad's violation of the Act. The Federal Employers' Liability Act of 1908 provides a cause of action for a railroad employee based on a violation of the Safety Appliance Act, in which he is required to prove only the statutory violation and the carrier is deprived of the defenses of contributory negligence and assumption of risk. Petitioner, a nonemployee of respondent railroad, sued in the Iowa courts for damages resulting from a defective coupler, in violation of the Safety Appliance Act. The jury, which was instructed that petitioner had "to establish by a preponderance or the greater weight of the evidence . . . that [he] was free from contributory negligence," returned a verdict for the railroad.
Held: In accordance with consistent interpretation of the statutory scheme, a nonemployee must look for his remedy to a common law action in tort, and, in the absence of diversity, must sue in a state court, and the definition of causation and the availability of the defenses of assumption of risk and contributory negligence are left to state law. Pp. 166-167.
___ Iowa ___, 160 N.W. & 838, affirmed.
Page 165
BRENNAN, J., lead opinion
MR. JUSTICE BRENNAN delivered the opinion of the Court.
The question in this case is whether a State may make the defense of contributory negligence available to a railroad sued by a nonemployee for damages for personal injuries caused by the railroad's failure to maintain its freight cars "with couplers coupling automatically by impact," as required by § 2 of the Federal [89 S.Ct. 1708] Safety Appliance Act of 1893, 27 Stat. 531, 45 U.S.C. § 2.1
Petitioner was in the employ of Cargill, Inc., at its Cedar Rapids, Iowa, meal house and elevator on the line of respondent railroad. Petitioner's duties were to move, weigh, and load freight cars spotted by respondent on Cargill's siding track. He was working on the top of the third of a string of six cars when a coupler malfunctioned and caused the first two cars to break away. Petitioner dismounted and ran to the runaway cars. He climbed to the roof of one and was attempting to apply its brake when he fell 12 to 14 feet to a cement apron between the tracks and suffered severe injuries. He brought this action in tort in the Iowa District Court of Linn County. The only claim submitted to the jury was that petitioner's injuries resulted from respondent's maintenance, in violation of § 2, of a freight car with a defective coupler. Over petitioner's objection, the jury was instructed in accordance with settled Iowa tort law that it was petitioner's burden "to establish by a preponderance or the greater weight of
Page 166
the evidence . . . that [he] was free from contributory negligence," defined as "negligence on the part of a person injured . . . which contributed in any way or in any degree directly to the injury." The jury returned a verdict for respondent railroad. The Supreme Court of Iowa affirmed, ___ Iowa ___, 160 N.W.2d 838 (1968). We granted certiorari. 393 U.S. 1047 (1969). We affirm.
The Safety Appliance Act did not create a federal cause of action for either employees or nonemployees seeking damages for injuries resulting from a railroad's violation of the Act. Moore v. C. & O. R. Co., 291 U.S. 205 (1934). Congress did, however, subsequently provide a cause of action for employees: the cause of...
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