2025 Ohio 819
Ohio Ct. App.2025Background
- Edward M. Wilson worked for CSX Transportation, Inc. as a track repairman and welder from 1978–2014, performing heavy manual labor.
- Wilson alleged CSX failed to provide adequate equipment (notably, a consistently working truck boom), and adequate assistance, leading to cumulative degenerative injuries to his knees, back, and neck, as well as two acute injuries in 2012 and 2013.
- Following surgery and disability retirement, Wilson filed FELA claims in state court after previous litigation attempts in Pennsylvania and procedural delays.
- The trial court granted summary judgment in favor of CSX on all of Wilson's claims, finding no triable issues of fact.
- On appeal, the court partially reversed, allowing Wilson’s cumulative injury claim based on lack of equipment to proceed to trial, but affirmed summary judgment for CSX on all other claims and theories.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Failure to provide adequate equipment | CSX’s failure to supply reliable boom forced unsafe lifting | Only normal job requirements; insufficiently unsafe | Enough evidence for jury—remand on this theory |
| Failure to provide adequate assistance | Inadequate helper increased workload and risk | No sufficient knowledge or foreseeability of risk | No breach of duty; summary judgment for CSX affirmed |
| Failure to train, warn, or assess hazards | Absence of JHAs, training, warnings increased risk | No evidence these precautions would have altered outcome | No causation; summary judgment for CSX affirmed |
| Acute injury (2012 and 2013 incidents) | CSX negligence caused/work conditions led to acute injuries | Incidents not reported; not linked causally to conditions | No causation established; summary judgment affirmed |
Key Cases Cited
- Atchison, Topeka & Santa Fe Ry. Co. v. Buell, 480 U.S. 557 (scope of FELA liability and broad construction)
- CSX Transp., Inc. v. McBride, 564 U.S. 685 (liberal FELA causation standard; any part, even the slightest)
- Gallick v. Baltimore & Ohio RR. Co., 372 U.S. 108 (duty/foreseeability under FELA distinct from common law)
- Urie v. Thompson, 337 U.S. 163 (cumulative workplace injury claims are actionable under FELA)
- Rogers v. Missouri Pacific RR. Co., 352 U.S. 500 (jury question if employer’s negligence played any part in injury)
- Wilkerson v. McCarthy, 336 U.S. 53 (jury determines reasonableness of employer’s conduct under the circumstances)