Brown v. Western Railway of Alabama

Brown (plaintiff) sued the Western Railway of Alabama (Western) (defendant) in Georgia state court under the Federal Employers’ Liability Act, under which federal and state courts shared concurrent jurisdiction. According to Brown, he was injured when he stepped on debris that allegedly was negligently left lying along the railroad track where Brown was standing. Specifically, Brown asserted that Western allowed debris to be left alongside its track despite knowing about the danger that such debris posed to workers and that Western violated its duty to provide him with a safe work environment. The trial court dismissed Brown’s case, ruling that Brown failed to state a cause of action. The court of appeals affirmed, opining that the fact that debris was left next to the track, standing alone, did not constitute negligence. In reaching this conclusion, the court of appeals applied a Georgia rule of practice that allegations in a pleading should be construed most strongly against the pleader. Thus, the court ruled that without any allegations to the contrary, it should infer that Brown could have seen and avoided stepping on the debris. The Georgia Supreme Court denied Brown’s petition for a writ of certiorari. Brown appealed, arguing that Georgia could not restrict his federal rights under the act by imposing an onerous local procedural pleading rule. Western countered that although state courts could not restrict a plaintiff’s substantive rights under the act, state courts were free to follow their own practices and procedures even in cases arising under the act.