Joseph Hall v. BNSF Railway Company, 958 F.3d 672

Plaintiff Joseph Hall slipped on a defective train crossover and injured his shoulder; he sued BNSF under the Safety Appliance Act and sought damages under the Federal Employers’ Liability Act (FELA).
Pretrial both parties initially proposed a generic damages instruction based on Eighth Circuit Model Instruction 15.70; Hall later submitted a more specific instruction listing pain and mental suffering, future pain and suffering, and lost earnings.
The district court rejected Hall’s specific instruction, explaining the evidence was insufficient to support future damages, and also declined to add Hall’s suggested bullet points; it instead gave a generic Instruction No. 13 permitting recovery for any damages the jury found Hall sustained.
The jury awarded Hall $35,000 (an amount similar to his lost-wages claim). Hall moved for a new trial; the district court denied the motion. He appealed, arguing entitlement to the more specific damages instruction.
The Eighth Circuit held Hall preserved his objection at trial, reviewed the instruction decision for abuse of discretion, and affirmed because the generic instruction adequately covered the requested specifics and did not affect Hall’s substantial rights.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion by refusing Hall's requested specific damages instruction	Hall argued the evidence supported specific categories (pain and mental suffering, future pain, lost earnings) and thus he was entitled to a specific instruction	BNSF argued the court properly rejected the specific instruction because evidence was insufficient for future damages and the generic instruction was adequate	Court held no abuse of discretion: generic instruction permitted recovery for any damages, covered the substance of Hall's request, and any error did not affect substantial rights

Retz v. Seaton, 741 F.3d 913 (abuse-of-discretion standard; no error when given instructions cover substance of requested instruction)
McCoy v. Augusta Fiberglass Coatings, Inc., 593 F.3d 737 (district courts have broad discretion in jury instructions)
Lincoln Composites, Inc. v. Firetrace USA, LLC, 825 F.3d 453 (instructions reviewed as a whole in light of evidence and law)
Phillips v. Collings, 256 F.3d 843 (reversal requires instructional error affecting substantial rights)
Chicago & N.W. Ry. Co. v. Green, 164 F.2d 55 (distinguishes entitlement to specific instruction on a party's theory of the accident)
Kehoe v. Anheuser-Busch, Inc., 96 F.3d 1095 (preservation of jury-instruction objections)
Bd. of Water Works Tr. of Des Moines v. Alvord, Burdick & Howson, 706 F.2d 820 (trial court not bound to give party's requested instruction)