CSX Transportation, Inc. v. McBride
564 U.S. 685
SCOTUS2011Background
- McBride, a locomotive engineer for CSX, was injured using a hand-operated brake during switching on a local CSX-run.
- McBride sued CSX under FELA, alleging unsafe equipment and inadequate training.
- District Court instruction allowed recovery if CSX’s negligence “played any part” in causing the injury, without requiring proximate causation.
- CSX requested proximate-cause instructions; the court rejected them and adopted the Seventh Circuit pattern instruction based on Rogers.
- Seventh Circuit affirmed the jury verdict for McBride under the “any part” causation standard.
- CSX petitioned for certiorari to challenge the Rogers-based causation standard in FELA actions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rogers’s “any part” test governs FELA causation. | McBride relies on Rogers as the general FELA standard. | CSX contends Rogers was misread and requires a direct/proximate relation as in traditional torts. | Yes, Rogers’s test governs FELA causation as the standard. |
| Whether the trial court could refuse CSX’s proximate-cause definitions. | Rogers instruction already provides sufficient causation guidance. | A proximate-cause definition is necessary to avoid unlimited liability. | The court may refuse traditional proximate-cause definitions; the Seventh Circuit instruction suffices. |
| Whether FELA requires traditional proximate-cause analysis or allows a relaxed standard. | FELA’s language and prior decisions support a relaxed standard. | Traditional proximate-cause concepts should apply. | FELA permits a relaxed causation standard and does not require traditional proximate-cause formulations. |
| Whether Congress intended to abrogate proximate-cause in FELA by using “resulting in whole or in part from”. | Latin phrasing signals broader liability under FELA. | Congress intended only to abolish contributory negligence, not proximate cause. | The text abrogates contributory negligence, not proximate cause; proximate-cause concept remains relevant. |
Key Cases Cited
- Rogers v. Missouri Pacific R. Co., 352 U.S. 500 (1957) (established the FELA causation standard (any part, however small))
- Consolidated Rail Corp. v. Gottshall, 512 U.S. 532 (1994) (FELA’s remedial purpose and relaxed causation standard)
- Gallick v. Baltimore & Ohio R. Co., 372 U.S. 108 (1963) (recognizes causation where negligence played any part in producing injury)
- Coray v. Southern Pacific Co., 335 U.S. 520 (1949) (advocated simple, direct statutory language over common-law dialectics)
- Sorrell v. United States, 549 U.S. 158 (2007) (discussed FELA’s causation scope and proximate-cause interpretation)
- Urie v. Thompson, 337 U.S. 163 (1949) (proximately cause standard in FELA context)
- Davis v. Wolfe, 263 U.S. 239 (1923) (early articulation of proximate-cause requirement in negligence actions)