Dice v. Akron, Canton & Youngstown Railroad Co.

Dice (plaintiff) was a railroad fireman employed by the Akron, Canton & Youngstown Railroad (the railroad) (defendant). Dice was injured while working. Dice sued the railroad in Ohio state court for negligence under the Federal Employers’ Liability Act (FELA). The railroad defended itself by claiming that Dice had signed a release of all his claims. Dice claimed that the railroad had falsely told him that the document he was signing was merely a receipt for backpay. The jury found for Dice. The trial court entered a judgment notwithstanding the verdict, which meant the trial judge overruled the jury verdict and entered judgment for the railroad. The trial judge’s basis for this action was that under Ohio state law, Dice was responsible for failing to read the release he had signed, regardless of what the railroad had told him. Dice appealed. The Ohio Court of Appeals reversed, ruling that federal law governed Dice’s federal claim. Under federal law, a fraudulent release was invalid, and a judge could not overrule a jury’s verdict that was supported by evidence. The railroad appealed to the Ohio Supreme Court, which reversed and held that (1) state law controlled a case heard in state court and (2) under Ohio law, fraud issues were properly determined by the judge instead of the jury. The United States Supreme Court granted certiorari.