Atchison T. & S. F. R. Co. v. Buell - 480 U.S. 557 (1987)
U.S. Supreme Court
Atchison T. & S. F. R. Co. v. Buell, 480 U.S. 557 (1987)
Atchison, Topeka & Santa Fe Railway Co. v. Buell
Argued December 1, 1986
Decided March 24, 1987
480 U.S. 557
Under the Federal Employers' Liability Act (FELA), railroad workers can sue their employers for personal injuries suffered at the hands of the employers or fellow employees. The Railway Labor Act (RLA) provides for the submission of minor labor disputes in the railroad industry to binding arbitration. Respondent, a carman employed by petitioner, filed an FELA suit in Federal District Court, alleging that petitioner had condoned his harassment by fellow employees, causing him to suffer an emotional breakdown. The District Court granted petitioner summary judgment, holding that the RLA precluded an FELA remedy. The Court of Appeals reversed, holding that respondent's claims were not arbitrable under the RLA, and that an FELA action was therefore not precluded. Additionally, although the question had been neither raised by the parties nor addressed by the District Court, the Court of Appeals held that purely emotional injury is compensable under the FELA.
1. The fact that an injury was caused by conduct that may have been subject to arbitration under the RLA does not deprive a railroad employee of his right to bring an FELA action for damages. The FELA not only provides substantive protection against conduct that is independent of the employer's obligations under its collective bargaining agreement, but also affords injured workers a remedy suited to their needs, unlike the limited relief of backpay and reinstatement that is available through RLA arbitration. Although the RLA minor disputes remedy is exclusive "in at least some circumstances," it is not exclusive in situations that the FELA was enacted to address. Pp. 480 U. S. 564-566.
2. Petitioner's argument that, even if many workplace injuries are actionable under the FELA, the RLA requires that a narrow "emotional injury" exception be carved out of the FELA because of the close relationship of such injuries to minor disputes that must be brought under the RLA is not persuasive. There is no basis for assuming that allowing FELA emotional injury actions will wreak havoc with the RLA's general arbitration scheme, and absent an intolerable conflict between the two
statutes, this Court is unwilling to read the RLA as repealing any part of the FELA. Pp. 480 U. S. 566-567.
3. The record is insufficient at this preliminary stage to allow this Court, or the Court of Appeals, to express an opinion on respondent's ultimate chance of recovery under the FELA on his emotional injury claim. The question whether purely emotional injury is compensable under the FELA is not necessarily an abstract point of law or a pure question of statutory construction susceptible to an all-inclusive "yes" or "no" answer. It might require exacting scrutiny of each case's facts in light of developing legal principles. Pp. 480 U. S. 567-571.
771 F.2d 1320, affirmed in part, vacated in part, and remanded.
STEVENS, J., delivered the opinion for a unanimous Court.