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Consolidated Rail Corp. v. Gottshall

United States Supreme Court
512 U.S. 532 (1994)


James Gottshall (plaintiff) sued his employer, Consolidated Rail Corporation (Conrail) (defendant), under the Federal Employers’ Liability Act (FELA) after Gottshall developed severe depression and post-traumatic stress disorder following an episode in which a coworker died of a heart attack. The district court granted Conrail’s motion for summary judgment, but the United States Court of Appeals for the Third Circuit reversed on the ground that genuine issues of material fact existed regarding the foreseeability of Gottshall’s injury and the unreasonableness of Conrail’s conduct. In a separate matter, Alan Carlisle (plaintiff) sued Conrail under FELA after suffering from a nervous breakdown and depression following a period in which Carlisle was subjected to long working hours in a stressful environment. A jury found in Carlisle’s favor. On appeal, the Third Circuit affirmed, concluding that Carlisle’s injury was genuine and foreseeable and that Conrail’s stressful work environment constituted a breach of its duty to maintain a safe workplace. Conrail petitioned the Supreme Court for certiorari regarding both decisions of the Third Circuit.

Rule of Law


Holding and Reasoning (Thomas, J.)

Concurrence (Souter, J.)

Dissent (Ginsburg, J.)

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