FELA
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| FELA | |
|---|---|
| Name | FELA |
| Long name | Federal Employers' Liability Act |
| Type | United States federal statute |
| Enacted by | United States Congress |
| Effective date | 1908 |
| Citation | 45 U.S.C. §51 et seq. |
| Status | amended |
FELA is a United States federal statute enacted in 1908 to provide a civil remedy for railroad employees injured on the job. It establishes liability standards distinct from common law negligence and from state workers' compensation schemes, creating a federal cause of action against interstate common carriers. The act has shaped litigation involving railroad safety, influenced labor law disputes involving American Federation of Labor allies, and prompted a series of Supreme Court rulings that define employer liability and evidentiary burdens.
Background and History
FELA was passed amid public debate following high-profile accidents involving carriers such as the Baltimore and Ohio Railroad and the Pennsylvania Railroad, and political pressure generated by labor leaders including Samuel Gompers and organizations like the Brotherhood of Locomotive Engineers. Congressional deliberations drew testimony from engineers, conductors, and representatives of the Interstate Commerce Commission and the United States Bureau of Labor Statistics. The statute superseded narrow common-law remedies highlighted in cases involving carriers like the New York Central Railroad and responded to state statutes such as the Illinois Workmen's Compensation Act and rulings in Wisconsin and Pennsylvania courts that limited employees' recovery. Early amending debates invoked legislators from the Progressive Era and intersected with reforms promoted during the administrations of Theodore Roosevelt and William Howard Taft.
Legal Framework and Provisions
FELA creates a cause of action against interstate common carriers and affiliates including the Atchison, Topeka and Santa Fe Railway and the Southern Pacific Railroad for injuries "resulting in whole or in part" from the employer's negligence. The statute's operative language contrasts with statutes like the Federal Employers' Liability Act's state-law counterparts and interacts with provisions of the Federal Employers Liability Act codified at 45 U.S.C. §51 et seq., prescribing remedies for death and injury and authorizing compensatory damages including for pain and suffering. Key provisions allocate burdens concerning contributory negligence; unlike the New York Central R.R. v. White common-law rules, FELA rejects absolute bars and instead apportions fault. The act limits punitive recoveries but allows plaintiffs to aggregate claims for lost wages and medical expenses against carriers such as the Union Pacific Railroad and the Chicago, Burlington and Quincy Railroad. Jurisdictional clauses tie suits to federal courts including the United States District Court for the Southern District of New York and appellate review in the United States Court of Appeals for the Second Circuit and Supreme Court of the United States.
Implementation and Enforcement
Enforcement occurs through private litigation by injured employees and through actions by families in wrongful-death suits invoking statutes related to the Civil Rights Act. Plaintiffs often enlist litigators with experience against defendants like Conrail and CSX Transportation. Administrative interactions involve agencies such as the National Mediation Board and regulatory considerations under the Federal Railroad Administration. Trial procedures require jury determinations on negligence issues, guided by precedents from the United States Supreme Court and circuits including the D.C. Circuit and the Ninth Circuit. Settlements with large carriers often follow investigations parallel to inquiries by the Occupational Safety and Health Administration and accident reports filed with the National Transportation Safety Board. Enforcement is shaped by discovery practices and evidentiary standards developed in litigation against corporations such as Amtrak.
Major Cases and Precedents
Supreme Court decisions have clarified FELA's scope. In Chicago, Burlington & Quincy Railroad Co. v. United States and later in Baltimore & Ohio Railroad Co. v. Goodman the Court addressed proximate cause and contributory negligence principles. Landmark rulings including Dixon v. United States and Consolidated Rail Corp. v. Gottshall defined causation standards and preemption questions regarding employee remedies and workplace safety regulations. The Court's opinion in Norfolk & Western Railway Co. v. Ayers elaborated on damages for pain and suffering and the evidentiary framework for exposure claims. Circuit precedents from the Second Circuit and Seventh Circuit have addressed liability for chronic exposure claims involving carcinogens and asbestos as found in litigation against companies like Union Carbide and railroad defendants. The doctrine of apportionment articulated in cases such as McBride v. Milwaukee and interpreted by courts including the Eighth Circuit remains central to FELA trials.
Impact and Criticism
FELA altered the balance between labor advocates like A. Philip Randolph and corporate interests represented by transport firms, increasing litigation against carriers such as the New York, New Haven and Hartford Railroad. Supporters credit the statute with incentivizing safety reforms at yards operated by Burlington Northern and motivating investments overseen by regulators like the Federal Railroad Administration. Critics—including some scholars at institutions such as Harvard Law School and commentators in publications tied to the American Enterprise Institute—argue FELA fosters inconsistent jury results and litigation costs that burden carriers and shippers represented by the Chamber of Commerce of the United States. Debates also touch on comparative frameworks in other jurisdictions, contrasting FELA with compensation systems in Canada and the United Kingdom and with legislative reforms such as the Federal Employers' Liability Act amendments proposed in multiple congressional cycles.
Related Legislation and International Context
FELA interacts with federal statutes and state laws, including the Federal Employers' Liability Act's interplay with occupational statutes administered by the Occupational Safety and Health Administration and reporting regimes of the National Transportation Safety Board. Legislative cousins include the Jones Act governing seamen and the Longshore and Harbor Workers' Compensation Act. Internationally, comparative labor law scholars reference frameworks like the UK Railways Act and Canadian provincial workers' compensation statutes in provinces such as Ontario and Quebec when evaluating FELA's unique mixture of tort principles and statutory remedy. Periodic proposals in the United States Congress and hearings before committees such as the House Committee on Transportation and Infrastructure continue to shape amendment prospects.