Texas & Pacific Ry. Co. v. Rigsby - 241 U.S. 33 (1916)
U.S. Supreme Court
Texas & Pacific Ry. Co. v. Rigsby, 241 U.S. 33 (1916)
Texas & Pacific Railway Company v. Rigsby
Argued February 21, 1916
Decided April 17, 1916
241 U.S. 33
Disregard of the Safety Appliance Act is a wrongful act, and, where it results in damage to one of the class for whose especial benefit it was enacted, the right to recover the damages from the party in default is implied -- ubi jus ibi remedium.
An employee of a railroad company has a right of action against the company for damages sustained by reason of defective appliances in violation of the Safety Appliance Act even though he was engaged at the time in intrastate, and not interstate, commerce.
Congress may, in the exercise of the plenary power to regulate commerce between the states, require installation of safety appliances on cars used on highways of interstate commerce irrespective of the use made of any particular car at any particular time.
When Congress enters a field of regulation within its paramount authority, state regulation of that subject matter is excluded, and so held that, without leave of Congress, a state can no more make or enforce laws inconsistent with the Federal Safety Act giving redress for injuries to workmen or travelers occasioned by absence or insecurity of such safety devices than it can prescribe the character of the appliances.
The right of private action by an employee injured while engaged in duties unconnected with interstate commerce, but injured by a defect in a safety appliance required by act of Congress, has such relation to the operation of such act as a regulation of interstate commerce that it is within the constitutional grant of authority to Congress over that subject.
Although § 4 of the Safety Appliance Act of 1910 relieves the carrier from statutory penalties while a car is being hauled to the nearest available point for repairs, it does not relieve the carrier from liability in a remedial action for the death or injury of an employee caused by, or in connection with, the movement of a defectively equipped car.
Whether the defective condition of a car under the Federal Safety Appliance Act is or is not due to negligence of the carrier is immaterial, as the Act imposes an absolute and unqualified duty to maintain the appliance in secure condition; nor under § 8 of the Act of 1893 and § 5 of the Act of 1910 is an employee deemed to have assumed the risk although continuing in the employment after knowledge of the defect.
222 F. 221 affirmed.
The facts, which involve the construction of the Safety Appliance Act and the validity of a verdict against the carrier, are stated in the opinion.