Crane v. Cedar Rapids & I. C. R. Co., 395 U.S. 164 (1969)

Crane v. Cedar Rapids & Iowa City Railway Co.

No. 791

Argued April 24, 1969
Decided May 26, 1969
395 U.S. 164

CERTIORARI TO THE SUPREME COURT OF IOWA

Syllabus

The Federal Safety Appliance Act of 1833 requires interstate railroads to equip freight cars "with couplers coupling automatically by impact," but does not create a federal cause of action for employees or nonemployees seeking damages for injuries resulting from a railroad’s violation of the Act. The Federal Employers’ Liability Act of 1908 provides a cause of action for a railroad employee based on a violation of the Safety Appliance Act, in which he is required to prove only the statutory violation and the carrier is deprived of the defenses of contributory negligence and assumption of risk. Petitioner, a nonemployee of respondent railroad, sued in the Iowa courts for damages resulting from a defective coupler, in violation of the Safety Appliance Act. The jury, which was instructed that petitioner had "to establish by a preponderance or the greater weight of the evidence . . . that [he] was free from contributory negligence," returned a verdict for the railroad.

Held: In accordance with consistent interpretation of the statutory scheme, a nonemployee must look for his remedy to a common law action in tort, and, in the absence of diversity, must sue in a state court, and the definition of causation and the availability of the defenses of assumption of risk and contributory negligence are left to state law. Pp. 166-167.

___ Iowa ___, 160 N.W. & 838, affirmed.