Collins v. Central Railroad of Indiana
1:19-cv-00692
| S.D. Ohio | Jun 26, 2025Background
- John Collins, a conductor for the Central Railroad of Indiana (CIND), injured his shoulder in October 2018 while attempting to set a ratchet-style handbrake on a railcar.
- Collins asserts the injury occurred due to a defective, poorly maintained handbrake that seized and then suddenly released, causing his injury.
- CIND investigated and found the handbrake was defective due to lack of lubrication and seized parts, with a lubricating port painted over; after lubrication, the handbrake operated properly.
- Collins sought damages under the Federal Employers' Liability Act (FELA) and the Federal Safety Appliance Act (FSAA), alleging CIND's negligence and statutory violation.
- Both parties filed motions for summary judgment: CIND argued Collins was the sole cause of his injury due to his use of extra force; Collins argued CIND's violation of the FSAA entitled him to summary judgment on liability.
- The court denied both motions, finding genuine issues of material fact regarding causation suitable for a jury.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Collins was sole cause of injury | Collins acted reasonably in response to a faulty brake. | Collins applied excessive force against training. | Fact issue for jury; summary judgment denied |
| FSAA violation as basis for FELA claim | Defective handbrake is a per se violation of FSAA. | Doesn't contest defect, but argues causation lacking. | Genuine issue of causation; summary judgment denied |
| Effect of employee violating training | Violation of procedure does not bar FELA claim if employer negligence also present. | Any violation of safety procedure defeats claim. | Employee mistakes do not bar FELA recovery if employer negligence plays any part |
| Standard for summary judgment under FELA | Summary judgment only if no reasonable jury could find for plaintiff. | CIND claims sole cause bars claim. | Issue for jury; summary judgment inappropriate |
Key Cases Cited
- Urie v. Thompson, 337 U.S. 163 (FELA causation standard is broadly interpreted to include any employer negligence that plays a part in injury)
- CSX Transp., Inc. v. McBride, 564 U.S. 685 (affirming that even slight employer negligence permits a FELA case to reach the jury)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard)
- Rogers v. Missouri Pac. R.R. Co., 352 U.S. 500 (test for submission to jury under FELA is whether employer negligence played any part)
- Norfolk Southern Ry. Co. v. Sorrell, 549 U.S. 158 (FELA provides for comparative, not contributory, negligence and abolishes assumption of risk defense)