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Alabama Great Southern R.R. Co. v. Carroll
Supreme Court of Alabama
11 So. 803 (1892)
W.D. Carroll (plaintiff), an Alabama citizen, was employed as a brakeman under an Alabama contract with the Alabama Great Southern Railroad Company (Alabama Southern) (defendant). While working on a freight train running from Alabama to Mississippi, Carroll was injured on account of a defective link between two cars. The injury occurred in Mississippi, but Carroll alleged that its cause happened in Alabama. Evidence showed that fellow employees of Carroll were negligent in failing to discover the defect or remedy it. Carroll sued Alabama Southern in Alabama court. He alleged that the employment contract rendered Alabama Southern subject to Alabama law even if Carroll were working outside of the state. If Mississippi law were applicable, Alabama Southern could not be liable because Mississippi subscribed to the common law rule that a master is not liable for harm to a servant caused by a fellow servant. An Alabama employers’ liability statute, however, modified the common law in that state so as to make a master liable for injury to a servant. A jury decided in favor of Carroll. Alabama Southern appealed.
Rule of Law
Holding and Reasoning (McClellan, J.)
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