Huffman v. Union Pacific Railroad
675 F.3d 412
| 5th Cir. | 2012Background
- Huffman, a long-time Union Pacific employee, sues under FELA for knee osteoarthritis allegedly caused by repeated railway work and the railroad’s failures in safety training and ergonomics.
- He claims negligent failure to provide a reasonably safe work environment, warnings/training, ergonomic analysis, and a comprehensive plan to reduce physical stresses.
- Evidence showed Huffman performed trainman duties (lifting, climbing, ballast walking, coupling/uncoupling) and developed knee osteoarthritis after retirement.
- Union Pacific argued there was no evidence linking his specific knee condition to work-related negligence and moved for JMOL; district court denied.
- Trial included neither party presenting expert causation testimony; Huffman presented lay and expert-like testimony through ergonomics experts, but the district court excluded treating-physician causation testimony.
- The Fifth Circuit reverses the jury verdict, holding the record shows insufficient evidence that the railroad’s negligence contributed to Huffman’s knee osteoarthritis; remands for entry of judgment in favor of Union Pacific.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of causation evidence under FELA | Huffman: jurors may infer causation from cumulative evidence without expert causation testimony | Union Pacific: insufficient probative evidence tying railroad negligence to Huffman’s osteoarthritis | Insufficient causation evidence; error to affirm verdict; reverse and remand for judgment for Union Pacific |
| Need for expert testimony on causation | Gutierrez-like proof acceptable; no expert required for CTD-type claims | Expert causation required for linking work to knee osteoarthritis | No definitive rule requiring expert testimony; court found record insufficient without explicit causation link from evidence, so reversal stands |
| Judicial estoppel issue on inconsistent positions | Union Pacific was estopped from arguing lack of work-related causation | No clear inconsistency; positions were alternatives or not clearly adopted | Issue waived/insufficient to disturb outcome; not relied upon for the reversal |
Key Cases Cited
- CSX Transp., Inc. v. McBride, 131 S. Ct. 2630 (2011) (any part, even the slightest, standard of causation under FELA)
- Rivera v. Union Pac. R.R. Co., 378 F.3d 502 (5th Cir. 2004) (FELA jury standard; complete absence of probative facts)
- Gutierrez v. Excel Corp., 106 F.3d 683 (5th Cir. 1997) (CTD proof without expert causation in some contexts)
- Rogers v. Mo. Pac. R.R. Co., 352 U.S. 500 (1957) (FELA causation general standard pre-McBride)
- Fontenot v. Teledyne Movible Offshore, Inc., 714 F.2d 17 (5th Cir. 1983) (jurors may infer from evidence; role of inference in FELA)
- Lavender v. Kurn, 327 U.S. 645 (1946) (standard for sufficiency review in FELA context)