Worcester v. Springfield Terminal Railway Co.
827 F.3d 179
| 1st Cir. | 2016Background
- Plaintiff Jason Worcester, a Springfield Terminal Railway employee, was fired after disputing safety steps for cleaning a hydraulic fluid spill reported to Maine DEP on Oct. 6, 2011.
- Worcester sued under the Federal Railroad Safety Act (FRSA) whistleblower provision, 49 U.S.C. § 20109.
- Jury awarded $150,000 in compensatory and $250,000 in punitive damages; Springfield appealed the punitive damages instruction.
- Springfield timely filed a Rule 59 motion for a new trial and later withdrew it during a court conference; the district court treated withdrawal as an order disposing of the motion, triggering the appeal clock.
- The First Circuit held it had jurisdiction because the withdrawal constituted an order disposing of the motion, making Springfield’s notice of appeal timely.
- On the merits, the court affirmed the district court’s punitive-damages jury instruction adopting the Smith v. Wade (reckless-disregard) standard and declined to apply differing state-law punitive standards.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the appeal timely when Springfield withdrew its Rule 59 motion? | Withdrawal did not constitute an "order disposing of" the motion, so appeal time not tolled. | Withdrawal (with court acceptance) disposed of the motion and tolled the appeal clock. | Court: Withdrawal accepted by judge was an order disposing of the motion; appeal timely. |
| What standard governs punitive damages under the FRSA? | FRSA (plaintiff) supports using the federal/common-law standard (Smith) as interpreted by DOL/ARB. | Springfield: Apply Maine state-law standard (malice) because case is in Maine federal court. | Court: Use national/common-law standard (Smith reckless-disregard); district court instruction correct. |
| Is the DOL/ARB interpretation of FRSA punitive-damages standard entitled to deference? | Plaintiff: ARB/agency interpretation supports Smith standard and is persuasive. | Springfield: Agency interpretation not entitled to Chevron deference. | Court: Even without Chevron, ARB’s interpretation is persuasive (Skidmore) and consistent with Congress’s uniformity goal. |
| Would adopting a uniform federal/common-law standard impermissibly create federal general common law? | Plaintiff: Federal courts may adopt common-law meanings for statutory terms; Congress likely intended common-law definitions. | Springfield: Using a national common-law standard intrudes on Erie and forbids general federal common law. | Court: Interpreting a federal statute’s common-law term does not create forbidden federal general common law; reliance on common-law principles is appropriate. |
Key Cases Cited
- Smith v. Wade, 461 U.S. 30 (1983) (adopts reckless-disregard standard for punitive damages under § 1983)
- Erie R. Co. v. Tompkins, 304 U.S. 64 (1938) (no federal general common law)
- Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984) (framework for agency deference to statutory interpretations)
- Skidmore v. Swift & Co., 323 U.S. 134 (1944) (agency interpretations entitled to persuasive weight under circumstances)
- Microsoft Corp. v. i4i Ltd. P'ship, 564 U.S. 91 (2011) (courts may rely on common-law background when interpreting statutory terms)
- Director, Office of Workers' Comp. Programs v. Greenwich Collieries, 512 U.S. 267 (1994) (use of common-law principles to interpret statutory burdens)
- Carey v. Piphus, 435 U.S. 247 (1978) (consulting common law when construing damages under § 1983)