CSX Transportation, Inc. v. McBride
131 S. Ct. 2630
| SCOTUS | 2011Background
- McBride, a locomotive engineer for CSX, injured his hand using an independent brake during a switching run between Indiana and Illinois.
- McBride filed a FELA action alleging CSX negligence in requiring unsafe switching equipment and in failing to train him.
- District Court refused CSX's proximate-causation instructions and gave a Rogers-like instruction that negligence need only 'play any part—no matter how small' in bringing about the injury.
- Seventh Circuit affirmed the instruction, holding Rogers governs FELA causation and that proximate-cause formulations should not be imported into FELA.
- CSX challenged, arguing Rogers relaxes causation too far and requests a more direct/proximate-cause standard.
- Court granted certiorari to determine the proper causation standard in FELA and whether Rogers should control.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the Rogers 'any part' causation standard proper for FELA? | McBride urged Rogers; any part suffices. | CSX urged a traditional proximate-cause standard requiring a direct/efficient cause. | Yes; Rogers is proper and sufficient for FELA causation. |
| Should proximate-cause terminology be imported or rejected in FELA? | Rogers provides a workable, jury-understandable standard. | Stock proximate-cause terms are preferable to avoid limitless liability. | Stock proximate-cause terms need not be adopted; the Rogers-based 'played any part, even the slightest' test remains appropriate. |
Key Cases Cited
- Rogers v. Missouri Pacific R. Co., 352 U.S. 500 (1957) (establishes the 'any part' causation standard in FELA)
- Gallick v. Baltimore & Ohio R. Co., 372 U.S. 108 (1963) (recognizes relaxed FELA causation standard and foreseeability context)
- Gottshall v. Consolidated Rail Corp., 512 U.S. 532 (1994) (confirms FELA's relaxed causation relative to common law)
- Sorrell v. United States, 549 U.S. 158 (2007) (discusses FELA proximate cause and Rogers in context of common-law)
- Coray v. Southern Pacific Co., 335 U.S. 520 (1949) (notes FELA uses simple and direct statutory language over common-law notions)