Consolidated Rail Corporation v. Gottshall (1993)
- Docket
- 92-1956
- Decided
- 1993-01-01
Summary
Question: Under the Federal Employers' Liability Act (FELA), does "emotional stress" resulting from employer "negligence" constitute an "injury" for which an employee can hold his employer liable? Conclusion: No. Justice Clarence Thomas authored the opinion for a 7-2 Court. The Court categorized FELA emotional stress claims closely with common law treatments of emotional stress claims. The Court rejected the Third Circuit's assertion that common law tests were arbitrary and could be disregarded. Instead, common law standards should be used to verify claims filed under FELA. The Court adopted the "zone of danger test" from common law, which limits relief to those employees who sustain physical injury resulting from emotional stress caused by employer negligence. The Court held that this test would best distinguish between genuine and fraudulent claims, and provide relief in the case of injury. The Court rejected the Third Circuit's holding that employers were liable for causing foreseeably stressful conditions, reasoning that this would extend to many types of everyday employment.