Martin v. BNSF Railway Co.
Annotate this CasePlaintiff was injured while working as a switchman/brakeman for BNSF Railway Company. Plaintiff later brought this action against BNSF under the Federal Employers’ Liability Act (FELA) alleging negligence. The jury returned a verdict in BNSF’s favor on negligence and strict liability claims for violations of the Locomotive Inspection Act (LIA). The district court subsequently denied Plaintiff’s motion for judgment as a matter of law or, in the alternative, motion for a new trial. The Supreme Court affirmed in part, reversed in part, and remanded for a new trial, holding that the district court (1) did not err by allowing Plaintiff’s LIA claim to be considered by the jury; (2) did not abuse its discretion by excluding evidence of heated platforms at BNSF’s Whitefish and Essex depots; but (3) abused its discretion by admitting into evidence the specific amount of income Plaintiff made from his non-railroad employment.
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