Norfolk & Western Ry. Co. v. Hiles, 516 U.S. 400 (1996)

Norfolk & Western Ry. Co. v. Hiles

No. 95-6

Argued January 8, 1996
Decided February 27, 1996
516 U.S. 400

ON WRIT OF CERTIORARI TO THE APPELLATE COURT

OF ILLINOIS, FIFTH DISTRICT

Syllabus

Railroad cars are connected by couplers consisting of knuckles-clamps that lock with their mates-joined to the ends of drawbars, which are fastened to housing mechanisms on the cars. Cars automatically couple when they come together and one car’s open knuckle engages the other car’s closed knuckle. The drawbar pivots in its housing, allowing the knuckled end some lateral play to prevent moving cars from derailing on a curved track. As a consequence of this lateral movement, drawbars may remain off-center when cars are uncoupled, and must be realigned manually to ensure proper coupling. Respondent Hiles injured his back while attempting to realign an off-center drawbar on a car at one of petitioner Norfolk & Western Rail Company’s yards. He sued in Illinois state court, alleging that Norfolk & Western had violated § 2 of the Safety Appliance Act (SAA or Act), which requires that cars be equipped with "couplers coupling automatically by impact, and capable of being uncoupled, without the necessity of individuals going between the ends of the vehicles." The trial court granted Hiles a directed verdict on liability, and the State Appellate Court affirmed.

Held: Section 2 does not makes a railroad liable as a matter of law for injuries incurred by a railroad employee while trying to straighten a misaligned drawbar. Pp. 403-414.

(a) Congress passed the SAA in 1893 to promote switchyard safety by requiring the use of standardized automatic couplers. SAA liability may be predicated on the failure of coupling equipment to perform as required by the Act, and the SAA creates an absolute duty requiring not only that automatic couplers be present, but also that they actually perform. See, e.g., Affolder v. New York, C. & St.L. R. Co., 339 U.S. 96, 98. Pp. 403-409.

(b) However, failure to couple will not cause a violation if the railroad can show that a coupler has not been properly set to couple on impact. Affolder, supra, at 99. Affolder’s restriction on "failure to perform" liability logically extends to every step necessary to prepare a nondefective coupler for coupling, including ensuring a drawbar’s proper alignment. Thus, the absolute duty is not breached as a matter of law when a drawbar becomes misaligned during the ordinary course of railroad operations. Hiles’ interpretation would require a finding that, as a matter of law, a misaligned drawbar is a malfunctioning drawbar, when, in fact, misalignment occurs as a part of the normal course of railroad car operations. His reading of § 2 would mean that every railroad car for nearly a century has been in violation of the SAA. Also contrary to Hiles’ argument, § 2 does not command railroads to develop a mechanism for automatic drawbar realignment. Congress legislated working automatic couplers for employee safety, not employee safety by whatever means a court might deem appropriate. Pp. 409-414.

268 Ill. App.3d 561, 644 N. E.2d 508, reversed.

THOMAS, J., delivered the opinion for a unanimous Court.