Dice v. Akron, Canton & Youngstown R. Co.
342 U.S. 359 (1952)

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U.S. Supreme Court

Dice v. Akron, Canton & Youngstown R. Co., 342 U.S. 359 (1952)

Dice v. Akron, Canton & Youngstown Railroad Co.

No. 374

Argued December 3-4, 1951

Decided February 4, 1952

342 U.S. 359

Syllabus

1. In an action in a state court under the Federal Employers' Liability Act, the question of the validity of a release granted to the carrier by the injured employee is a federal question, and is to be determined by federal, rather than state, law. Pp. 342 U. S. 361-362.

2. A release of rights under the Federal Employers' Liability Act is void when the employee is induced to sign it by deliberately false and material statements of the carrier's authorized representatives, made to deceive the employee as to the contents of the release. P. 342 U. S. 362.

3. In an action brought under the Federal Employers' Liability Act in an Ohio state court, which provides jury trials for cases arising under the Act, it was error for the judge to take from the jury the determination of the factual questions as to whether a release had been fraudulently obtained. Pp. 342 U. S. 362-364.

155 Ohio St. 185, 98 N.E.2d 301, reversed.

In a state court action under the Federal Employers' Liability Act, the State Supreme Court sustained a judgment for the defendant notwithstanding a verdict of the jury in favor of the plaintiff. 155 Ohio St. 185, 98 N.E.2d 301. This Court granted certiorari. 342 U.S. 811. Reversed and remanded, p. 342 U. S. 364.

Page 342 U. S. 360

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Primary Holding

State courts have the power to adjudicate federal claims, but they should not use state laws to determine the scope of federal rights.

Facts

When an engine owned by the Akron, Canton & Youngstown Railroad Co. jumped the track, it struck and injured a railroad fireman named Dice. He brought a negligence claim in Ohio state court under the Federal Employers' Liability Act. The railroad produced a document in which Dice purportedly released it from all liability beyond the amount of $925 that he had already received. Dice responded by asserting that the railroad had fraudulently told him that the document was a receipt for that amount and that he had not read it before signing it.

After the jury found for Dice, the judge granted the railroad's motion for judgment notwithstanding the verdict because it ruled that Dice could not avoid the obligations created by signing the release. Ohio state law imposed a duty on him to read the document before signing it. However, federal law would have held that the railroad's fraud precluded the enforcement of the release, and the state appellate court reversed on this basis. The state supreme court reversed again.

Opinions

Majority

  • Hugo Lafayette Black (Author)
  • Frederick Moore Vinson
  • William Orville Douglas
  • Tom C. Clark
  • Sherman Minton

The effect of federal laws would be undermined if the rights that they provided could be forestalled by defenses that would arise only under state law. Judges in state courts do have the authority to resolve issues of fraud that arise in negligence actions, but the federal system provides the right to a jury trial as an essential function in its process.

Concurrence/Dissent In Part

  • Felix Frankfurter (Author)
  • Stanley Forman Reed
  • Robert Houghwout Jackson
  • Harold Hitz Burton

Case Commentary

When a situation is controlled by federal law, it must be applied in a consistent way so that the purpose of the U.S. Congress is effectuated.

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