Supreme Court Rules on Causation Standard Applicable to Maritime Injuries

The Sky's the limit. Or so says Chief Justice Roberts who, in dissent, thought that injured rairoad workers should have to show that their injuries were proximately caused by their employers. The Supreme Court rejected that interpretation of the statute and held that proximate cause was not fairly read into the Federal Employer's Liability Act. So, in Roberts words, the Court abandoned a causation standard that is bounded in reason, in favor of one that knows no bounds. The Supreme Court just handed down a decision interpreting the causation standard in the Federal Employer's Liability Act, 45 U.S.C. 51, et seq. or FELA. The case is CSX v. McBride, and the decision can be downloaded here. In short, the Supreme Court found that FELA does not have a proximate cause standard for causation but rather the applicable standard is that a defendant is liable if, "a defendant railroad caused or contributed to a plaintiff employee's injury if the railroad's negligence played any part in bringing about the injury." This case is important to maritime injury practitioners because the Jones Act incorporates the provisions of FELA. Once again, "maritime" cases make for strange bedfellows with Justice Thomas providing the fifth vote, joining the Court's traditionally "liberal" justices. Chief Justice Roberts, writing in dissent, thought that the decision was boundless in its impact. Facts: The injured employee was an engineer working for CSX. He suffered a hand injury while working and permanently lost function of the hand. He brought a FELA suit in federal court alleging that CSX was negligent in providing him unsafe working equipment and by failing to train him in operating the equipment. CSX sought a jury instruction that required a proximate cause, which would require direct showing of negligence to injury. The trial court refused and this appeal followed. The Supreme Court, in a decision authored by Justice Ginsburg, noted that the railroad business is a hazardous one and FELA was enacted to shift the burden of the danger from the individual employees to the employers. In tort law, an injured party can only recover damages if the tortfeasor was the legal cause or proximate cause of the injury. This reflects the policy determination that only those injuries legally caused by another ought to be compensable. CSX argued that by not using a proximate cause standard, employers faced heightened exposure. In fact, in his dissent, Chief Justice Roberts called the causation standard upheld by the court to be a "boundless theory of liability." Despite the fact that the courts of appeal had upheld jury instructions like the one in the instant case, Chief Justice Roberts chided such a notion of Supreme Court review: The Court is correct that the federal courts of appeals have read Rogers to support the adoption of instructions like the one given here. But we do not resolve questions such as the one before us by a show of hands. Chief Justice Roberts found that there is a strong policy consideration requiring inclusion of proximate cause in the FELA regime. The chain of causation from negligent act to injury is to tenuous without an overlay of proximate or legal cause. For: It is useful to ask whether the injury that resulted was within the scope of the risk created by thedefendant's negligent act; whether the injury was a natural or probable consequence of the negligence; whether there was a superseding or intervening cause; whether the negligence was anything more than an antecedent event without which the harm would not have occurred. Then, the CJ gets a little punchy: Law has its limits. But no longer when it comes to the causal connection between negligence and a resulting injury covered by FELA. A new maxim has replaced the old: Caelum terminus est -the sky's the limit.

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