Norfolk and Western Ry. v. Hiles

• Decision Date: 27 February 1996
• Docket Number: 956
• Citation: 134 L.Ed.2d 34,516 U.S. 400,116 S.Ct. 890
• Parties: NORFOLK AND WESTERN RAILWAY COMPANY, Petitioner, v. William J. HILES
• Court: U.S. Supreme Court

516 U.S. 400

116 S.Ct. 890

134 L.Ed.2d 34

NORFOLK AND WESTERN RAILWAY COMPANY, Petitioner,

v William J. HILES.

No. 95-6.

Supreme Court of the United States

Argued Jan. 8, 1996.

Decided Feb. 27, 1996.

Syllabus*

Railroad cars are connected by couplers consisting of knuckles—clamps that lock with their mates —joined to the ends of drawbars, which are fastened to housing mechanisms on the cars. Cars automatically couple when they come together and one car's open knuckle engages the ot her car's closed knuckle. The drawbar pivots in its housing, allowing the knuckled end some lateral play to prevent moving cars from derailing on a curved track. As a consequence of this lateral movement, drawbars may remain off-center when cars are uncoupled and must be realigned manually to ensure proper coupling. Respondent Hiles injured his back while attempting to realign an off-center drawbar on a car at one of petitioner Norfolk & Western Rail Company's yards. He sued in Illinois state court, alleging that Norfolk & Western had violated § 2 of the Safety Appliance Act (SAA or Act), which requires that cars be equipped with "couplers coupling automatically by impact, and capable of being uncoupled, without the necessity of individuals going between the ends of the vehicles." The trial court granted Hiles a directed verdict on liability, and the State Appellate Court affirmed.

Held: Section 2 does not makes a railroad liable as a matter of law for injuries incurred by a railroad employee while trying to straighten a misaligned drawbar. Pp. __-__.

(a) Congress passed the SAA in 1893 to promote switchyard safety by requiring the use of standardized automatic couplers. SAA liability may be predicated on the failure of coupling equipment to perform as required by the Act, and the SAA creates an absolute duty requiring not only that automatic couplers be present, but also that they actually perform. See, e. g., Affolder v. New York, C. & St. L.R. Co., 339 U.S. 96, 98, 70 S.Ct. 509, 510, 94 L.Ed. 683. Pp. __-__.

(b) However, failure to couple will not cause a violation if the railroad can show that a coupler has not been properly set to couple on impact. Affolder, supra, at 99, 70 S.Ct., at 510-511. Affolder's restriction on failure-to-perform liability logically extends to every step necessary to prepare a nondefective coupler for coupling, including ensuring a drawbar's proper alignment. Thus, the absolute duty is not breached as a matter of law when a drawbar becomes misaligned during the ordinary course of railroad operations. Hiles' interpretation would require a finding that, as a matter of law, a misaligned drawbar is a malfunctioning drawbar, when, in fact, misalignment occurs as a part of the normal course of railroad car operations. His reading of § 2 would mean that every railroad car for nearly a century has been in violation of the SAA. Also contrary to Hiles' argument, § 2 does not command railroads to develop a mechanism for automatic drawbar realignment. Congress legislated working automatic couplers for employee safety, not employee safety by whatever means a court might deem appropriate. Pp. __-__.

268 Ill.App.3d 561, 205 Ill.Dec. 952, 644 N.E.2d 508, reversed.

THOMAS, J., delivered the opinion for a unanimous Court.

On Writ of Certiorari to the Appellate Court of Illinois, Fifth District.

Carter G. Phillips, Washington, DC, for petitioner.

Lawrence M. Mann, New Orleans, LA, for respondent.

Justice THOMAS delivered the opinion of the Court.

Before us in this case is the question whether § 2 of the Safety Appliance Act (SAA), 49 U.S.C.A. § 20302(a)(1)(A) (Supp.1995), makes a railroad liable as a matter of law for injuries incurred by a railroad employee while trying to straighten a misaligned drawbar. We hold that it does not and, accordingly, reverse the judgment of the Illinois Appellate Court.

I

Railroad cars in a train are connected by couplers located at both ends of each car. A coupler consists of a knuckle joined to the end of a drawbar, which itself is fastened to a housing mechanism on the car. A knuckle is a clamp that interlocks with its mate, just as two cupped hands—placed palms together with the fingertips pointing in opposite directions—interlock when the fingers are curled.¹ When cars come together, the open knuckle on one car engages a closed knuckle on the other car, automatically coupling the cars. The drawbar extends the knuckle out from the end of the car and is designed to pivot in its housing, allowing the knuckled end some lateral play to prevent moving cars from derailing on a curved track. As a consequence of this lateral movement, drawbars may remain off-center when cars are uncoupled. This misalignment, if not corrected, may prevent cars from coupling by allowing the knuckles to pass by each other. To ensure proper coupling, railroad employees must realign drawbars manually.

Respondent William J. Hiles was a member of a switching crew at petitioner Norfolk & Western Railway Company's Luther Yard in St. Louis, Missouri. His duties included coupling and uncoupling railroad cars and aligning drawbars. On July 18, 1990, Hiles injured his back while attempting to realign an off-center drawbar. Hiles sued in Illinois state court, alleging that Norfolk & Western had violated the SAA, which requires that cars be equipped with "couplers coupling automatically by impact, and capable of being uncoupled, without the necessity of individuals going between the ends of the vehicles." 49 U.S.C.A. § 20302(a)(1)(A) (Supp.1995). Norfolk and Western argued that the misaligned drawbar did not result from defective equipment. The trial court granted Hiles' motion for directed verdict on liability.

The Illinois appellate court affirmed. 268 Ill.App.3d 561, 205 Ill.Dec. 952, 644 N.E.2d 508 (1994). The Illinois Appellate Court recognized a deep split of authority over the proper interpretation of the SAA, but determined that it would not reconsider its "longstanding authority permitting a plaintiff . . . to recover under the Safety Appliance Act for injuries sustained while attempting to align a misaligned drawbar." Id., at 565, 205 Ill.Dec., at 955, 644 N.E.2d, at 511. The Illinois Supreme Court denied review, and we granted certiorari, 515 U.S. ----, 116 S.Ct. 40, 132 L.Ed.2d 921 (1995), to resolve the conflict among the lower courts.²

II

A

For most of the nineteenth century, the link-and-pin coupler was the standard coupler used to hook together freight cars. It consisted of a tubelike body that received an oblong link. During coupling, a railworker had to stand between the cars as they came together and guide the link into the coupler pocket. Once the cars were joined, the employee inserted a pin into a hole a few inches from the end of the tube to hold the link in place. See J. White, American Railroad Freight Car 490 (1993) (hereinafter White). The link-and-pin coupler, though widely used, ultimately proved unsatisfactory because (i) it made a loose connection between the cars with too much give and play; (ii) there was no standard design and train crews often spent hours trying to match pins and links while coupling cars; (iii) links and pins were frequently lost, resulting in substantial replacement costs; and (iv) crew members had to go between moving cars during coupling and were frequently injured and sometimes killed. Id., at 490-497.

In 1873, Eli H. Janney patented a knuckle-style coupler that was to become the standard for the freight car couplers used even today.³ See Figure 1. The coupler had a bifurcated drawhead and a revolving hook, which, when brought in contact with another coupler, would automatically interlock with its mate.

[NOTE: MATERIAL SET AT THIS POINT IS NOT DISPLAYABLE (GRAPHIC OR TABULAR MATERIAL)]

The Janney coupler had several advantages over link-and-pin couplers. Not only did it alleviate the problem of loose parts that plagued the link-and-pin coupler,⁴ it also allowed railworkers to couple and uncouple cars without having to go between the cars to guide the link and set the pin.⁵ One commentator described the automatic coupling operation as follows:

"While the cars were apart, the brakeman had to make sure the knuckle of the coupler on the waiting car stood in an open position and that the pin had been lifted into its set position. When the opposite coupler was closed and locked in position, the brakeman was able to stand safely out of the way and signal the engineer to move the cars together. When the knuckle of the coupler of the moving car hit the lever arm of the revolving knuckle on the open coupler, it revolved around the locked one, while concurrently the locking pin dropped automatically from its set position into the coupler, locking the knuckle in place. Although the brakeman had to set up the entire situation by hand, the actual locking operation was automatic and did not require the brakeman to stand between the cars." Clark 191.

Though the market was flooded with literally thousands of patented couplers,⁶ Janney's design was clearly among the best and slowly achieved recognition in the industry. See id., at 193-201. In 1888, the Master Car Builders Association Executive Committee obtained a limited waiver of patent rights—placing much of Janney's design in the public domain—and adopted the design as its standard. Conversion to the new standard proceeded slowly,⁷ partly as a result of the sheer number of competing designs on the market. The lack of standardized couplers itself caused safety problems,⁸ and reformers pushed Congress to pass legislation requiring the use of standardized automatic couplers.

In 1893, satisfied that an automatic coupler could meet the demands of commercial railroad operations and, at the same time, be manipulated safely, see Clark 206, Congress passed the Safety Appliance Act. Its success in promoting switchyard safety was stunning. Between 1877 and 1887, approximately 38% of all railworker accidents involved...