CSX TRANSP., INC. V. McBRIDE 131 S.Ct. 2630 (2011) CASE BRIEF

CSX TRANSP., INC. V. McBRIDE

131 S.Ct. 2630 (2011)

NATURE OF THE CASE: CSX (D) appealed a verdict in favor of McBride (P), which was affirmed by the Seventh Circuit, in a FELA action over a proximate cause jury instruction that was denied.

FACTS: P worked as a locomotive engineer for D, which operates an interstate system of railroads. A train P was to operate had an unusual engine configuration: two 'wide-body' engines followed by three smaller conventional cabs. P protested that the configuration was unsafe, because switching with heavy, wide-body engines required constant use of a hand-operated independent brake. P was told to take the train as is. P injured his hand while using the independent brake. Despite two surgeries and extensive physical therapy, he never regained full use of the hand. P sued under FELA alleging that D was twice negligent requiring P to use equipment unsafe for switching and for the failure to train him to operate that equipment. App. 24a-26a. The District Court instructed a verdict for P, if the jury found that D 'was negligent' and that the 'negligence caused or contributed to' P's injury. D sought additional charges that the court declined to give that 'the plaintiff show that ... the defendant's negligence was a proximate cause of the injury' and another to have defined 'proximate cause' to mean 'any cause which, in natural or probable sequence, produced the injury complained of,' with the qualification that a proximate cause 'need not be the only cause, nor the last or nearest cause.' The District Court used the pattern instruction for FELA cases, which reads: 'Defendant `caused or contributed to' Plaintiff's injury if Defendant's negligence played a part-no matter how small-in bringing about the injury. The mere fact that an injury occurred does not necessarily mean that the injury was caused by negligence.' P got the verdict. D appealed renewing its objection to the failure to instruct on 'proximate cause.' D 'maintain[ed] that the correct definition of proximate causation is a `direct relation between the injury asserted and the injurious conduct alleged.'' The Court affirmed the District Court holding that the Rogers case had 'relaxed the proximate cause requirement' in FELA cases. The Supreme Court granted certiorari.

ISSUE:

RULE OF LAW:

HOLDING AND DECISION:

LEGAL ANALYSIS:

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