Norfolk Southern Railway Co. v. Sorrell (2006)

Docket
05-746
Decided
2006-01-01

Summary

Question: Is the causation standard for employee negligence under the Federal Employers Liability Act different from the causation standard for railroad negligence? Conclusion: No. The Court ruled unanimously that the causation standard for employee negligence is the same as the standard for railroad negligence. The opinion by Chief Justice John Roberts held that "the common law applied the same causation standard to defendant and plaintiff negligence, and FELA did not expressly depart from that approach." In the absence of any explicit indication from the text of FELA, the Court relied on common law principles of negligence. The Court held that Congress had most likely intended for juries to compare each party's contribution under the same standard - a simple "apples to apples" comparison. The Court ruled only that the causation standards were the same; it declined to rule on the question of what the standard of causation should be.

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