A general classification in a state statute resting upon obvious
principles of public policy does not offend the equal protection
provision of the Fourteenth Amendment because it includes persons
not subject to a uniform degree of danger.
An employee. of a railway company, although not engaged in the
actual operation of trains, is nevertheless within the general line
of hazard inherent in the railway business.
A state statute abrogating the fellow servant rule as to
employees of railway companies is not unconstitutional under the
equal protection provision of the Fourteenth Amendment because it
applies to all employees, and not only to those engaged in the
actual operation of trains, and so
held as to § 3559 of
the Mississippi Constitution of 1890.
Legislation providing that proof of one fact shall constitute
prima facie evidence of the main fact is within the
general power of government to enact rules of evidence, and neither
due process of law nor equal protection of the law is denied if
there is a rational connection between the fact and the ultimate
fact presumed, and the party affected
Page 219 U. S. 36
is afforded reasonable opportunity to submit to the jury all the
facts on the issue.
It is not an unreasonable inference that a derailment of railway
cars is due to negligence in construction, maintenance, or
operation of the track or of the train, and the provisions of §
1985 of the Mississippi Code of 1906 making proof of injury
inflicted by the running of cars or locomotives of a railway
company
prima facie evidence of negligence on the part of
servants of the company does not deprive the companies of their
property without due process of law or deny to them the equal
protection of the law.
Such a statute, in its operation, only supplies an inference of
liability in the absence of other evidence contradicting such
inference.
The facts, which involve the constitutionality under the equal
protection clause of the Fourteenth Amendment of certain provisions
of the Code and of the Constitution of the Mississippi, are stated
in the opinion.
Page 219 U. S. 39
MR. JUSTICE LURTON delivered the opinion of the Court.
This was an action in tort for the wrongful killing of Ray
Hicks, a section foreman in the service of the railroad company.
There was a judgment for the plaintiff in a circuit court of the
State of Mississippi, which was affirmed by the supreme court of
the state.
The federal questions asserted which are supposed to give this
Court jurisdiction to review the judgment of the supreme court of
the state arise out of the alleged repugnancy of §§ 3559 and 1985
of the Mississippi Code to that clause of the Fourteenth Amendment
of the Constitution which guarantees to every person the equal
protection of the laws.
Page 219 U. S. 40
Section 3559 of the Mississippi Code of 1892, being a rescript
of § 193 of the Mississippi Constitution of 1890, abrogates,
substantially, the common law fellow servant rule as to "every
employee of a railroad corporation." It is urged that this
legislation, applicable only to employees of a railroad company, is
arbitrary, and a denial of the equal protection of law unless it be
limited in its effect to employees imperiled by the hazardous
business of operating railroad trains or engines, and that the
Mississippi Supreme Court had, in prior cases, so defined and
construed this legislation.
Ballard v. Mississippi Cotton Oil
Co., 81 Miss. 532;
Bradford Construction Co. v.
Heflin, 88 Miss. 314.
It is now contended that the provision has been construed in the
present case as applicable to an employee not subject to any danger
or peril peculiar to the operation of railway trains, and that
therefore the reason for such special classification fails, and the
provision, so construed and applied, is invalid as a denial of the
equal protection of the law.
This contention, shortly stated, comes to this: that, although a
classification of railway employees may be justified from general
considerations based upon the hazardous character of the
occupation, such classification becomes arbitrary and a denial of
the equal protection of the law the moment it is found to embrace
employees not exposed to hazards peculiar to railway operation.
But this Court has never so construed the limitation imposed by
the Fourteenth Amendment upon the power of the state to legislate
with reference to particular employments as to render ineffectual a
general classification resting upon obvious principles of public
policy, because it may happen that the classification includes
persons not subject to a uniform degree of danger. The insistence
therefore that legislation in respect of railway employees
generally is repugnant to the clause of the Constitution
Page 219 U. S. 41
guaranteeing the equal protection of the law, merely because it
is not limited to those engaged in the actual operation of trains,
is without merit.
The intestate of the defendant in error was not engaged in the
actual operation of trains. But he was nevertheless engaged in a
service which subjected him to dangers from the operation of
trains, and brought him plainly within the general legislative
purpose. The case in hand illustrates the fact that such employees,
though not directly engaged in the management of trains, are
nevertheless within the general line of hazard inherent in the
railway business. The deceased was the foreman of a section crew.
His business was to keep the track in repair. He stood by the side
of the track to let a train pass by; a derailment occurred, and a
car fell upon him and crushed out his life.
In the late case of
L. & N. Railroad v. Melton,
218 U. S. 36, an
Indiana fellow-servant act was held applicable to a member of a
railway construction crew who was injured while engaged in the
construction of a coal tipple alongside of the railway track. This
whole matter of classification was there considered. Nothing more
need be said upon the subject, for the case upon this point is
fully covered by the decision referred to.
The next error arises upon the constitutionality of § 1985 of
the Mississippi Code of 1906. That section reads as follows:
"Injury to persons or property by railroads
prima facie
evidence of want of skill, etc. -- In all actions against railroad
companies for damages done to persons or property, proof of injury
inflicted by the running of the locomotives or cars of such company
shall be
prima facie evidence of the want of reasonable
skill and care on the part of the servants of the company in
reference to such injury. This section shall also apply to
passengers and employees of railroad companies."
The objection made to this statute is that the railroad
Page 219 U. S. 42
companies are thereby put into a class to themselves, and
deprived of the benefit of the general rule of law which places
upon one who sues in tort the burden of not only proving an injury,
but also that the injury was the consequence of some negligence in
respect of a duty owed to the plaintiff.
It is to be primarily observed that the statute is not made
applicable to all actions against such companies. Its operation is
plainly limited, first, to injuries sustained by passengers or
employees of such companies; second, to injuries arising from the
actual operation of railway trains or engines, and third, the
effect of evidence showing an injury due to the operation of trains
or engines is only "
prima facie evidence of the want of
reasonable skill and care on the part of the servants of the
company in reference to such injury."
The law of evidence is full of presumptions, either of fact or
law. The former are, of course, disputable, and the strength of any
inference of one fact from proof of another depends upon the
generality of the experience upon which it is founded. For a
discussion of some common law aspects of the subject,
see
Cincinnati &c. Ry. v. South Fork Coal Co., 139 F. 528
et seq.
Legislation providing that proof of one fact shall constitute
prima facie evidence of the main fact in issue is but to
enact a rule of evidence, and quite within the general power of
government. Statutes, national and state, dealing with such methods
of proof in both civil and criminal cases abound, and the decisions
upholding them are numerous. A few of the leading ones are
Adams v. New York, 192 U. S. 585,
192 U. S. 48 L.
ed. 575, 24 Sup.Ct. Rep. 372;
People v. Cannon, 139 N.Y.
32;
Horne v. Memphis &c. Ry., 1 Coldwell 72;
Meadowcroft v. People, 163 Ill. 56;
Commonwealth v.
Williams, 6 Gray, 1;
State v. Thomas, 144 Ala.
77.
We are not impressed with the argument that the Supreme Court of
Mississippi, in construing the act, has declared
Page 219 U. S. 43
that the effect of the statute is to create a presumption of
liability, giving to it thereby an effect in excess of a mere
temporary inference of fact. The statutory effect of the rule is to
provide that evidence of an injury arising from the actual
operation of trains shall create an inference of negligence, which
is the main fact in issue. The only legal effect of this inference
is to cast upon the railroad company the duty of producing some
evidence to the contrary. When that is done, the inference is at an
end, and the question of negligence is one for the jury, upon all
of the evidence. In default of such evidence, the defendant, in a
civil case, must lose, for the
prima facie case is enough
as matter of law.
The statute does not, therefore, deny the equal protection of
the law, or otherwise fail in due process of law, because it
creates a presumption of liability, since its operation is only to
supply an inference of liability in the absence of other evidence
contradicting such inference.
That a legislative presumption of one fact from evidence of
another may not constitute a denial of due process of law or a
denial of the equal protection of the law, it is only essential
that there shall be some rational connection between the fact
proved and the ultimate fact presumed, and that the inference of
one fact from proof of another shall not be so unreasonable as to
be a purely arbitrary mandate. So also it must not, under guise of
regulating the presentation of evidence, operate to preclude the
party from the right to present his defense to the main fact thus
presumed.
If a legislative provision, not unreasonable in itself,
prescribing a rule of evidence in either criminal or civil cases
does not shut out from the party affected a reasonable opportunity
to submit to the jury in his defense all of the facts bearing upon
the issue, there is no ground for holding that due process of law
has been denied him.
Tested by these principles, the statute as construed and
Page 219 U. S. 44
applied by the Mississippi court in this case is
unobjectionable. It is not an unreasonable inference that a
derailment of railway cars is due to some negligence, either in
construction or maintenance of the track or trains, or some
carelessness in operation.
From the foregoing considerations it must be obvious that the
application of the act to injuries resulting from "the running of
locomotives and cars" is not an arbitrary classification, but one
resting upon considerations of public policy, arising out of the
character of the business.
Judgment affirmed.