Carter v. Atlanta & St. Andrews Bay Ry. Co. - 338 U.S. 430 (1949)
U.S. Supreme Court
Carter v. Atlanta & St. Andrews Bay Ry. Co., 338 U.S. 430 (1949)
Carter v. Atlanta & St. Andrews Bay Railway Co.
Argued October 14, 1949
Decided December 19, 1949
338 U.S. 430
In this action under the Federal Employers' Liability Act and the Safety Appliance Act, based upon a charge of negligence and a charge of a violation of the Safety Appliance Act through the failure of an automatic coupler, held:
1. It was error to take from the jury the phase of the case involving the alleged violation of the Safety Appliance Act, since there was evidence upon which a jury could find a causal relation between the failure of the coupler and the plaintiff's injury. Pp. 338 U. S. 433-435.
(a) The duty imposed on an interstate railroad by the Safety Appliance Act to equip cars "with couplers coupling automatically by impact" is an absolute duty unrelated to negligence, and the absence of a "defect" cannot aid the railroad if the coupler was properly set and failed to couple. Pp. 338 U. S. 433-434.
(b) The fact that the coupler functioned properly on other occasions is immaterial. P. 338 U. S. 434.
(c) Once a violation of the Safety Appliance Act is established, only causal relation is in issue, since violation of that Act supplies the wrongful act necessary to ground liability under the Federal Employers' Liability Act, regardless of negligence. P. 338 U. S. 434.
(d) If the jury determines that defendant's violation of the Safety Appliance Act is "a contributory proximate cause" of the injury, it may find for plaintiff. P. 338 U. S. 435.
2. In an action under the Federal Employers' Liability Act based on general negligence, contributory negligence does not bar recovery, but affects only the amount of damages recoverable, and the trial court's instructions to the jury on this issue in this case were erroneous and were prejudicial to the plaintiff. Pp. 338 U. S. 435-437.
170 F.2d 719, reversed.
In an action under the Federal Employers' Liability Act, there was a verdict against plaintiff upon which the Federal District Court entered judgment for defendant. The Court of Appeals affirmed. 170 F.2d 719. This Court granted certiorari. 336 U.S. 935. Reversed, p. 338 U. S. 437.